Additional Dwelling Supplement guidance video - Revenue Scotland
However HMRC have changed their view. HMRC‚ s revised view is that section 162 cannot apply because the whole assets of the business have not been transferred. HMRC state that their revised view applies to incorporations from 30 April 2016. HMRC have confirmed that as the revised interpretation of the availability of section 162 relief and mixed partnerships will apply to incorporations from 30 April 2016 no grandfathering provisions for earlier incorporations are considered necessary.
The CIOT has written to HMRC to request that consideration should be given to a specific statutory relief so that section 162 TCGA 1992 relief is available when mixed memberships incorporate in the circumstances described.
The full correspondence can be found here.