Corporate Gains and Owner Reliefs
Company disposals, shares, reorganisations and CGT reliefs affecting corporate owners.
How to study the ATT Qualification
Use Finance Act 2025 for the 2026 tax papers, complete the three foundational CBEs early, apply professional ethics throughout and concentrate option practice on the one paper you will enter.
Core concepts
Concept 1
Company disposals produce corporation-tax chargeable gains under the corporate rules.
Exam cue: Separate company-level and shareholder-level consequences.
Concept 2
Share reorganisations and takeovers can defer recognition while preserving base cost.
Exam cue: Establish whether a reorganisation treatment applies before computing disposal.
Concept 3
Owner reliefs require separate analysis from the company's tax position.
Exam cue: Track deferred gains and replacement base costs.
Risk pitfalls and guardrails
Applying personal annual exemptions to a company.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Ignoring consideration form in a takeover.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Assuming relief at one level eliminates tax at the other.
Guardrail: Do not use an obsolete tax rate, assume a relief, ignore legal form, submit unsupported information or omit the relevant deadline and ethical response.
Memory anchors
Two taxpayers
Analyse company and owner separately.
Corporate gain
Compute consideration, allowable cost and corporate indexation where examinable.
Reorganisation
Qualifying share exchanges may roll existing base cost into new shares.
Owner relief
Check asset, company, office and holding conditions.
Deferred trail
Record where each deferred gain is carried.
Checkpoint rule
Do the check-up only after you can summarize each concept in one sentence and identify one dangerous pitfall from memory.
Knowledge Check (after reading)
Short check-up to confirm understanding of this module.
Check-up Questions
A company sells an investment for £900,000. Its allowable indexed base cost is £640,000 on the stated facts. What chargeable gain arises?
A trading company disposes of a 15% holding in another trading company after holding it for the required period. What exemption should be tested?
Answer all questions to submit.
Next step personalized recommendations
Continue learning
Move forward only after this module is stable.
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