Entity and buyer tests
A Type 1 PHE directly holds prescribed immovable property worth at least 50% of its tangible assets. Type 2 tests trace at least 50% beneficial interests in related Type 1 entities and aggregate the relevant property and tangible-asset values. A buyer’s acquisition qualifies when the buyer and associates already are, or become, significant owners. The regime does not apply to equity acquired before 11 March 2017.
Disposals and instruments
Qualifying disposals use first-in-first-out acquisition dates: equity acquired through 3 July 2025 has a three-year period; equity acquired from 4 July 2025 has four years. Physical and electronic contracts, transfers, gifts and trust instruments may be dutiable. Testamentary or assent transfers have the stated exclusion; scripless-share cases require examining whether any contract or instrument exists.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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