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Question 3a

On 10 June 2012, Delroy made a gift of 25,000 £1 ordinary shares in Dub Ltd, an unquoted trading company, to his son, Grant. The market value of the shares on that date was £240,000. Delroy had subscribed for the 25,000 shares in Dub Ltd at par on 1 July 2002. Delroy and Grant have elected to hold over the gain as a gift of a business asset.

Grant sold the 25,000 shares in Dub Ltd on 18 September 2012 for £240,000.

Dub Ltd has a share capital of 100,000 £1 ordinary shares. Delroy was the sales director of the company from its incorporation on 1 July 2002 until 10 June 2012. Grant has never been an employee or a director of Dub Ltd.

For the tax year 2012–13 Delroy and Grant are both higher rate taxpayers. Neither of them has made any other disposals of assets during the year.

Required:
(i) Calculate Grant’s capital gains tax liability for the tax year 2012–13. (3 marks)

(ii) Explain why it would have been beneficial for capital gains tax purposes if Delroy had instead sold the 25,000 shares in Dub Ltd himself for £240,000 on 10 June 2012, and then gifted the cash proceeds to Grant. (2 marks)

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