Income Tax Act 2007 section 442

Qualifying interests in land held jointly

Section 442 sets out the rules for claiming tax relief when a qualifying interest in land is held jointly by two or more persons and is disposed of to a charity.

• All joint owners must dispose of their entire beneficial interest in the land to a charity for any relief to be available
• Relief is only available to owners who are individuals, though qualifying companies (which are not themselves charities) may also be party to the arrangement
• The share of relief allocated to each individual owner must be agreed between all owners who are individuals or qualifying companies
• Where any owner is not an individual, total relief across both income tax and corporation tax provisions is capped at the relievable amount

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