Taxation of Chargeable Gains Act 1992 section 164H

Property companies etc. not to be qualifying companies

Section 164H excluded property investment and dealing companies from qualifying for rollover relief on reinvestment under Chapter 1A of the Act, but this provision was repealed for acquisitions made on or after 6 April 1998.

• Section 164H was part of Chapter 1A (sections 164A–164N), which provided rollover relief when gains were reinvested in qualifying companies.
• Under this section, companies whose business consisted wholly or mainly of dealing in or holding land and buildings were not treated as qualifying companies for the purposes of that relief.
• This meant that taxpayers could not defer chargeable gains by reinvesting proceeds into property investment or property dealing companies.
• The entire Chapter 1A, including section 164H, was repealed by the Finance Act 1998 and ceased to apply for acquisitions made on or after 6 April 1998.

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