Hi,
Can anyone advise whether holdover relief is available on a charge over property?
Trust holds charge over property, trustees now want to appoint property out to beneficiaries by cancelling the charge. Is the cancellation of the charge a "gift" for holdover relief and if so, how is it valued and is the base cost of the property then reduced by the resulting gain? There is nothing else so set the gain against for holdover purposes so assume, if indeed holdover relief is available, then it must be...
My thoughts are that there should be holdover relief "There is no restriction as to the type of asset which may qualify for deferral so long as an IHT charge arises on the gift". The charge is certainly an asset held by the trust...but what's stopping me thinking holdover is available is what is the gain being heldover against?!
Many thanks for any thoughts!
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