If, following relief on the transfer of assets to a non-resident (see ¶35300), a transferee disposes of the assets acquired after the shares held by the transferor have been sold, only the part of the deferred chargeable gain not dealt with in the earlier transaction is brought into account (see also ¶35310 and ¶35320).


(Applying the rule to the facts in the example in ¶35310 followed by that in ¶35320.) Fraction of chargeable gain brought into account on disposal by S Inc:

capital gain deferred on building





capital gain deferred on whole



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