Can anyone clarify the position here. A client wishes to settle shares which will carry ER as it is his personal company so if the shares are sold later within the next 4 years he would get ER on the deemed MV disposal value. However he would want to elect holdover if the shares have not been sold by the time he comes to have to pay CGT.
Ideally given the 4 year period, he would want to elect holdover by Jan 2021 but then revoke the election if the shares are sold later. Alternatively he would pay CGT if he could later claim holdover if the shares are not sold.
Checking various sources, one says that a holdover claim cannot be revoked but others say this is possible and HMRC even illustrate this in their guidance. Could a prior holdover election be revoked within the 4 year election period with tax and interest becoming payable or can tax be paid when due and an election made later with the CGT paid then recovered?
M J Consultants
Consultant with BDB Pitmans LLP London