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HMRC internal manual

Capital Gains Manual

Housing associations: housing action trusts

Housing Action Trusts (HATs) are statutory corporations created under Part III of the Housing Act 1988. They are not housing associations or trusts.

HATs acquire run-down properties from local authorities to redevelop the sites and rehouse the tenants. After redevelopment properties may be transferred to housing associations, to tenants under the `right to buy’ legislation, to registered social landlords or back to the local authority.

HATs are subject to Corporation Tax on chargeable gains in the same way as other companies. Relief may be obtained under Section 259 where properties are transferred to housing associations or to registered social landlords, see CG66635+.