Dwellings subject to ATED: disposals chargeable under TCGA92/S2B
As set out at CG73611, section 2B imposes a charge to capital gains tax on gains that are ATED-related (see CG73625+) and accrue on ‘relevant high value disposals’ of residential property in the UK. TCGA92/S2C gives the meaning of ‘relevant high value disposal’. It is a disposal that meets the four conditions A to D—
A. The disposal is a disposal, or part disposal, of a ‘chargeable interest’, see CG73617.
B. The chargeable interest disposed of has been, or been part of, a ‘single-dwelling interest’ at some time during the ‘relevant ownership period’ of the person making the disposal, see CG73618.
C. The person making the disposal, or in certain circumstances another person, has been liable to ATED in respect of the single-dwelling interest, see CG73619
D. The consideration for the disposal exceeds the ‘threshold amount’ for that disposal, see CG73620.