CG14650 - Assets disposed of: series of transactions: introduction

The object of TCGA92/S19 is to ensure that connected persons do not exploit the market value rule by transferring singly in a series of transactions assets which are worth more together than separately. For example, Mrs A may wish to transfer to her daughter a Chippendale dining table and chairs. The items singly are worth much less than their appropriate portion of the value of all of them together. If she makes a series of gifts of individual items, the rules in TCGA92/S17 and TCGA92/S18 would bring in only the market value of the single items as consideration. TCGA92/S19 enables us to look at the higher value of each piece taken together with the others.

For the restriction to the chattels exemption when a set of articles is disposed of piece by piece, see CG76631+.

TCGA92/S19 and TCGA92/S20 apply where

  1. a person disposes of assets to a connected person or persons by way of two or more gifts or other transactions AND
  2. those transactions occur within a period of 6 years ending on the date of the last of them - they are said to form 鈥榓 series of linked transactions鈥� AND
  3. the 鈥榦riginal market value鈥� of the assets disposed of is less than the 鈥榓ppropriate portion of the aggregate market value鈥� of the assets disposed of by all the transactions in the series, see CG14653 for definitions.