A three storey house is converted into three flats and the flat leases have 65 years left to run. The freehold was purchased by the management company in 1997 and the three leaseholders are the shareholders and directors of the management company. New 999 year leases are being granted at a peppercorn rent and no premium is being paid. Are there any adverse capital gains tax consequences to either the management company or the leaseholders?

Harriet is qualified to practice in England and Wales and Jersey. She has rights of audience before all courts in both jurisdictions. Harriet advises taxpayers in relation to UK tax matters. She advises on all direct tax matters for private and corporate clients as well as in the context of trusts and estates, and on indirect tax matters. In addition to advising extensively on traditional private client matters, Harriet has a particular interest in international matters such as double tax treaties, TIEAs, disclosure facilities and conflict of laws issues arising in a tax context. Harriet also has extensive experience of resolving disputes with HMRC in both direct and indirect tax matters. Her approach is always to give detailed and practical advice from the initial enquiry through to any tribunal hearing. She offers a full service, particularly advising on the conduct and settling of tax enquiries, which often results in a favourable conclusion at an early stage. She can advise and act in all forms of alternative dispute resolution with HMRC, as well as in traditional litigation.