Corporation Tax Act 2010 section 214

Qualifying interests in land held jointly

Section 214 deals with the conditions under which corporation tax relief is available when a qualifying interest in land is held jointly by two or more owners and is disposed of to a charity.

• Where two or more persons jointly own a qualifying interest in land (whether as joint tenants or tenants in common), relief may be available provided at least one owner is a qualifying company and all owners dispose of their entire beneficial interests to the charity.
• A qualifying company is any company that is not itself a charity; only qualifying companies among the joint owners may claim the relief.
• Where the relief conditions are met, each qualifying company among the owners can claim relief, and the calculation of the relievable amount is determined under section 215.
• If any of the joint owners is not a company (for example, an individual), the rules in section 205(2) to (4) for determining whether a disposal has taken place apply as though references to a company also include persons who are not companies.