Taxation of Chargeable Gains Act 1992 Schedule 7ZA paragraph 24

Meaning of "P"

Paragraph 24 defines who "P" refers to in the context of business asset disposals, distinguishing between direct individual disposals and disposals of trust business assets.

• For a material disposal of business assets, "P" is simply the individual making the disposal.
• For a disposal of trust business assets, "P" means any relevant beneficiary of the trust.
• When testing whether "P" meets the ownership and voting rights thresholds for trust disposals, all relevant beneficiaries are treated as a single combined body, with their individual percentages aggregated.
• Relevant beneficiaries include the qualifying beneficiary in relation to the disposal and any other beneficiary entitled to a share of the trust's gains under the special trust provisions.