This case came to us from another firm of accountants in London. It concerned a multi-million-pound capital gain that was made by a national chain and were looking for strategies to mitigate the tax payable. Having discussed the matter in detail with the accountants and the client’s future plans, we were able to find a few strategies for deferring the gain using rollover relief. The strategies involved offshore acquisitions of trading assets that still qualified for the relief. As the scenario was quite complex, in addition to the legislation and HMRC guidance, we had to base our planning on various tax cases that have been decided by the courts over the last 20 years on rollover relief. The ultimate result was that the client’s entire capital gain was deferred until the disposal of the newly acquired assets which could be another 15-20 years if not more.
Our analysis: Rollover relief is a lucrative relief that is often overlooked by accountants. It can be applied in a number of situations and allows substantial tax savings if planned and executed correctly.