Originally posted by TheCyclingProgrammer
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- The transfer takes places at the donors acquisition cost, thus the "ongoing" gain in the asset is maintained as the time of the transfer. So, if the shares wer subscribed for £100 this is thier value on the recipient.
- It is feasible that HMIT could attack using Ramsay. This is only really likely if the transfer occurs shortly before disposal to a 3rd party. e.g. some property is owned which has a current gain of 20k. This is then transferred in part to a spouse and sold. HMIT may want to ignore the sale and assess the full gain of 20k on the donor (thus giving approx 10k subject to CGT) rather than allowing 10k each.
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