There are three specific exceptions to the application of the deemed market-value rule.

Professional trustee

Where immediately after the transaction the buyer company holds the property as a professional trustee, i.e. the company holds the property as trustee in the course of a business carried on by it which consists of or includes the management of trusts. It is advisable that neither the transferor nor any connected persons hold any shares or interests in the corporate trustee.

Transfer from settlor

Where immediately after the transaction the company holds the property as trustee and the seller is connected with the company solely by virtue of CTA 2010, s. 1122(6), i.e. in his capacity as settlor of the trust.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.