[CTM34620] Residence: dual resident companies: anti-avoidance – limitation of other reliefs
Six different types of relief are within the scope of the legislation (see CTM34505) because they have the potential for avoidance. The reliefs concerned all relate to CG or capital allowance provisions. They are not available in the circumstances below.
•Where there is a transfer of an asset to a dual resident investing company from another member of the group, the no gain/no loss basis treatment of the member making the disposal under TCGA92/S171 (see CG47005 onwards) is denied by TCGA92/S171 (2).