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Pg 57, 242

Memorandum

Client: Ray

From: Tax Senior

Subject: Tax advice on Ray’s unincorporated business, Shanira’s gifts, and Kelly’s income
tax issues

Part (b):

Gift of house: (22/23)

MV of gift 360000

(Cost) (280000)

Gain 80000

Annual Exemption (12300)

Chargeable gain 67700

CGT @ 28% 18956

No double taxation relief will be available on the gift of house since there is no taxation on gains in the
country of xyz.

CGT is paid on 31 Jan after the end of fiscal year. So, the CGT payable date will be 31 Jan 24.

Gift of Painting: (23/24)

Market Value 7000

(Cost) (15000)

Capital Loss (8000)

Gift of shares:

MV of shares (7400 * 9.2) 68080

Cost (W1) (7400 * 1.6) (11840)

Gain 56240

Gain per share 7.6


Working 1:

Value of shares in Beem Plc (3700) 12960

Per share purchase price 3.6

Gain on takeover,

7400 shares in solaris (8.4 * 7400) 62160

Cash 14800

76960

Value received against a share of beem plc 20.8

Gain/share of beem chargeable at the time of takeover 4

Gain/share of beem deferred ((62160-12960)/3700) 13.2

Gain/share of solaris deferred ((62160-12960)/7400) 6.6

New cost per share of solaris plc ((62160/7400)-6.6) 1.8

Gift of shares should be divided into two gifts such that the loss from the gift of painting and annual
exemption of CGT is fully used for tax year 23/24 without creating any tax liability.

Number of shares in solaris plc that can be gifted without any CGT liability are:

Annual exempt amount 12300

Loss on gift of painting 8000

20300

Number of shares (20300 / 7.6) 2671

2671 shares in solaris plc can be gifted in tax year 23/24 without creating any CGT liability.

Inheritance Tax Implications:

There is no inheritance tax charged on gifts between spouses or civil partners. However, the gift of house
was before marriage and hence will be considered as potentially exempt transfer and no life time tax will
arise on the gift of house.

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