Whenever there is a transaction that does not take place at market value, it will be no surprise that typically there is a rule deeming market value to apply for tax purposes. This is perhaps most commonly seen in the context of CGT for transactions between connected parties and those not ‘at arm’s length’ but there are numerous provisions that can bite. Reliefs and exemptions apply in some circumstances. It is always wise to understand the reasons for the transaction and full circumstances of the respective parties to be able to identify potential issues and advise accordingly.
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Whenever there is a transaction that does not take place at market value, it will be no surprise that typically there is a rule deeming market value to apply for tax purposes. This is perhaps most commonly seen in the context of CGT for transactions between connected parties and those not ‘at arm’s length’ but there are numerous provisions that can bite. Reliefs and exemptions apply in some circumstances. It is always wise to understand the reasons for the transaction and full circumstances of the respective parties to be able to identify potential issues and advise accordingly.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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