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Individuals will not be able to claim ER on disposals of goodwill

on a transfer of a business to a related close company from

3 December 2014, as previously announced.

The government will review the ER treatment of academics who

dispose of shares in spin-out companies that use intellectual

property to which they have contributed.

Residential property

Private residence relief will be restricted where a property is

located in a jurisdiction in which a taxpayer is not tax resident.

In these circumstances the property will only be regarded as

the person’s only or main residence for a tax year in which the

person meets a 90-day test for time spent in the property over

the year.

Non-UK resident individuals, trusts, personal representatives

and narrowly controlled companies will become subject to tax

on gains on the disposal of UK residential property after 5 April


Capital gains tax wasting assets

Legislation will clarify that the capital gains exemption for

wasting assets only applies if the person selling the asset has used

it in their own business. The change will take effect from 1 April

2015 for corporation tax and 6 April 2015 for capital gains tax.

Inheritance tax (IHT) threshold

The IHT threshold remains at £325,000 for 2015/16.

Deeds of variation

The government will review the use of deeds of

variation for inheritance tax planning.

Inheritance tax and trusts

New rules will target tax avoidance

through the use of multiple trusts.

As announced in the Autumn

Statement 2014, the government will

not introduce a single settlement nil-rate band.


18 March 2015

page 9