CC

I am asking on behalf of BVI Co. A, which has requested a UTR for Corporation Tax filing in 2024. BVI Co. A wholly owns BVI Co. B for over 10 years, and B is dormant since incorporation. B bought one UK commercial property in 2016, paid stamp duty and earned rental income solely throughout the years. No other acquisitions / asset / business in B after 2016 acquisition.
In 2024, A sold entire shares of B to third parties. B is property rich asset because it owned one UK commercial property only. For the calculation of A's gain/loss on indirect disposal of UK land, as B bought the property but A sold the shares of B, are we going to use the property value or the share value as sales proceeds? Could we use total acquisition cost of property in 2016 when we calculate the gain/loss on indirect disposal of UK land?
I am quite confused with the below link. Thank you very much.
https://www.gov.uk/guidance/capital-gains-tax-for-non-residents-calculating-taxable-gain-or-loss?gad_source=1&gclid=CjwKCAjw68K4BhAuEiwAylp3kqn4_C3wFJra3tHK1HjbRGW7gboju9fatuezeXKg_dLAgbzd6q8ikRoCPPgQAvD_BwE

BVI Co. A wholly owns BVI Co. B for over 10 years, and B is dormant since incorporation. B bought one UK commercial property in 2016 with total purchase cost of GBP5million (including stamp duty and other incidental costs) and earned rental income solely throughout the years. No other acquisitions / asset / business in B after 2016 acquisition.
In 2024, A sold entire shares of B to third parties with an agreed property value of GBP4.1million making the total consideration of GBP4million. GBP4million includes share consideration of GBP1million and repayment of B's loan GBP3million. Market Value of the UK commercial property is GBP3.8million on the sale date. B is property rich asset. For the calculation of A's gain/loss on indirect disposal of UK land, what is the correct disposal proceeds and relevant tax base cost?
I am quite confused with the below link.
Thank you very much.
https://www.gov.uk/guidance/capital-gains-tax-for-non-residents-calculating-taxable-gain-or-loss?gad_source=1&gclid=CjwKCAjw68K4BhAuEiwAylp3kqn4_C3wFJra3tHK1HjbRGW7gboju9fatuezeXKg_dLAgbzd6q8ikRoCPPgQAvD_BwE

BVI Co. A wholly owns BVI Co. B for over 10 years, and B is dormant since incorporation. B bought one UK commercial property in 2016 with total purchase cost of GBP5million (including stamp duty and other incidental costs) and earned rental income solely throughout the years. No other acquisitions / asset / business in B after 2016 acquisition.
In 2024, A sold entire shares of B to third parties with an agreed property value of GBP4.1million making the total consideration of GBP4million. GBP4million includes share consideration of GBP1million and repayment of B's loan GBP3million. Market Value of the UK commercial property is GBP3.8million on the sale date. B is property rich asset. For the calculation of A's gain/loss on indirect disposal of UK land, what is the correct disposal proceeds and relevant tax base cost?
I am quite confused with the below link.
Thank you very much.
https://www.gov.uk/guidance/capital-gains-tax-for-non-residents-calculating-taxable-gain-or-loss?gad_source=1&gclid=CjwKCAjw68K4BhAuEiwAylp3kqn4_C3wFJra3tHK1HjbRGW7gboju9fatuezeXKg_dLAgbzd6q8ikRoCPPgQAvD_BwE