deed of assignment cgt

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• Capital Gains Tax

Private Residents Relief for CGT and Deed of Assignment

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Transferring rental income or property between spouses

Chris Broome – Chartered Financial Planner

Transferring rental income or property between spouses can offer significant financial benefits, including potential savings on Capital Gains Tax (CGT) and Inheritance Tax (IHT).

It’s a smart financial move for married couples or civil partners.

Here’s how you can go about it.

1. Transferring Rental Income:

You can seamlessly transfer rental income to your spouse using various methods:

a. Deed of Assignment: This allows you to assign the beneficial interest to your spouse, regardless of whether both of you are named on the property’s title.

b. Sever Joint Tenancy and Draft a Deed: If you own a buy-to-let property as joint tenants, you’ll need to change to tenants in common and then share the rental income through a deed. Don’t forget to complete Form 17 and attach the deed when declaring your income to HMRC.

c. Transfer of Equity: If the property is solely owned, you can add your partner to the legal title through a transfer of equity process. If there’s a mortgage, you’ll need consent from the mortgage lender and likely add your spouse’s name to the mortgage.

d. Sale and Purchase: This is a more expensive option where the current owner completely transfers the property to their spouse. It’s typically done as part of a divorce settlement.

Remember that you’re responsible for the tax on your share of the rent on the day it’s paid. Ensure you file your tax return and pay HMRC by January 31st for the previous year’s rental income up to April 5th. The sooner you act, the sooner you can declare income according to your desired shares.

2. Transferring Property:

Transferring property between spouses can lead to CGT and IHT savings. For instance, if a husband transfers a rental property to his wife, it’s usually exempt from CGT and IHT. Plus, if the wife pays a lower tax rate, the couple will have less income tax to pay on the rental income. When they sell the property, they’ll also pay less capital gains tax.

Transferring property before selling it can further reduce the CGT bill by utilising both personal allowances, effectively doubling the allowance for married couples and civil partners, provided it’s a genuine, outright gift. However, transfers to others, such as siblings or common-law spouses, will incur CGT, treating the transfer as a disposal for capital gain.

3. Stamp Duty Considerations:

While property transfers between spouses are exempt from CGT, be aware of stamp duty implications. No automatic stamp duty relief applies when transferring property to your spouse. Stamp duty land tax is based on consideration, which can include cash payments or assuming mortgage liability. If the new owner takes responsibility for a mortgage, they become liable for the stamp duty land tax.

4. Principal Private Residence Relief:

Keep in mind that if you currently benefit from principal private residence relief, it may be at risk when transferring property to a spouse. To qualify for this relief, the transferee spouse must have lived in the property as their principal private residence during the ownership period. If this condition isn’t met, the relief may be lost.

In summary , transferring rental income and property between spouses can yield substantial financial advantages, including tax savings.

Ensure you follow the right procedures and consider potential stamp duty and relief implications.

The process for transferring would not be overseen by us here at Longhurst. We would look to introduce you to an accountant in the first instance.

Please note:

This blog is for general information only and does not constitute advice.

The information is aimed at retail clients only.

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Everett assignments

How to assess the risk rating of your Everett assignment arrangements and our compliance approach.

Last updated 3 July 2022

What are Everett assignments

When a partner assigns their partnership interest to an individual or other entity (the assignee), it is usually an entity related to the partner (the assignor). These assignments are commonly known as Everett assignments, after the case Federal Commissioner of Taxation v Everett [1980] HCA 6 (Everett).

In the Everett case, Mr Everett practised in partnership with three other solicitors and held a 13% interest in the capital and income of the partnership. He executed a Deed of Assignment to assign 6/13ths of his share of the firm to his wife. The Commissioner assessed both Mr Everett and his wife on the assigned portion. The High Court found that the assignment was effective for tax purposes. Income payable to Mr Everett’s spouse was trust income, which was assessable in her hands only.

A similar type of assignment was undertaken in Commissioner of Taxation v Galland [1986] HCA 83 (Galland) where Mr Galland, a solicitor in a partnership assigned 49% of his share in the partnership to a related family trust.

Legal principles from Everett and Galland

The principles established by the High Court in Everett and Galland may be summarised as follows:

• A partner’s interest in a partnership is a 'chose in action', which is assignable in whole or in part by way of equitable assignment.
• The effect of this type of assignment is that the assignor holds that assigned partnership interest on trust for the assignee.
• The assignment does not make the assignee a partner in the partnership or give the assignee any entitlement to the assets, management or administration of the partnership or the right to inspection of books and accounts.
• As a partner's partnership interest is an entire chose in action, a partner's entitlement to participate in profits is not separate and severable from the interest of the partner.
• A partner's income is not income from personal exertion but income from property, with the property being the partner's fractional interest in the partnership.

Our risk assessment approach

Practical Compliance Guideline PCG 2021/4 Allocation of professional firm profits – ATO compliance approach clarifies how we assess the risk and our compliance approach relating to the allocation of profits within professional firms.

The PCG applies from 1 July 2022 and outlines that the risk assessment framework is only available to taxpayers if their arrangements are commercially sound and do not exhibit high-risk features.

Your arrangement would be materially different in principle to Everett and Galland and may be high risk where:

• it purports to admit an individual who is not an owner or equity holder in the partnership as a partner of the partnership
• a partner's relationship with the partnership has characteristics indicating that relationship is akin to a contractor or employee of the partnership.

We also consider a partner undertaking an Everett assignment as high risk if they:

• do not have rights to full participation in management and the benefits of partnership
• receive a fixed draw or salary when they have limited or no exposure to the risks and benefits associated with the performance of the partnership to that draw or salary
• are indemnified by partners for any professional liability in respect of actions against the partnership.

Example: high risk assignment by non-equity partner

Jamie is made a non-equity partner in Design Partnership, an engineering firm and:

• is not required to make a capital contribution
• has a fixed salary of $130,000
• has no right to vote or participate in the management of the firm.

She undertakes an Everett assignment of a portion of her interest in the partnership to her family discretionary trust. This assignment is considered high risk because it is materially different in principle to Everett and Galland such that Jamie does not have the full rights, entitlements and obligations of a partner.

If your Everett assignment has high risk features, the Commissioner is likely to give closer attention to the individual facts and circumstances of the arrangement. This includes a deeper consideration of whether anti-avoidance provisions, such as Part IVA, apply.

Our approach to assessing the risk associated with Everett assignments that do not exhibit high risk factors will be determined in accordance with the risk assessment framework set out in the PCG 2021/4 . For information on how we risk assess the profit allocation in professional firms, refer to Assessing the risk: allocation of profits within professional firms .

If you are unsure whether your arrangement has high-risk features and whether it would be considered high risk, email [email protected]

Everett assignments and small business CGT concessions

Since 8 May 2018, law changes limit access to the small business capital gains tax (CGT) concessions relating to Everett assignments.

Under these changes, the assignment of a partnership interest must meet an additional basic condition to access the concessions.

The changes ensure that the CGT concessions are only available for capital gains arising from CGT events that relate to rights or interests that entitle an entity to income or capital of a partnership by making that entity a partner of the partnership.

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Transfers of shares held in trust are not subject to tax

MANILA  -In corporate law, it is common practice for lawyers to handle transfers of shares of stock from nominees to their principals, or to new nominees. Prior to the Revised Corporation Code, which came into effect in February 2019, corporations were required to have at least five stockholders and directors, each holding a minimum of one share of stock in the company.

When establishing a corporation, business owners would often seek out nominees to hold a qualifying share in order to meet the requirement of five shareholders. Typically, these nominees are the trusted officers of the principal stockholder who, since they do not own the company, eventually move on to other employment opportunities, thereby severing their connection with the company.

In such cases, the nominees would execute a deed of assignment of the shares to return them to the principal or to the new nominee who will be taking their place.

Even with the introduction of the Revised Corporation Code which allows for less than five stockholders in a corporation, many companies still prefer to maintain several board seats in their board for various reasons, one of which is for good governance.

Accordingly, transfers of shares of stock from nominees to new nominees are quite common. Oftentimes, the transfer of shares is done by the execution of a deed of assignment by the nominee to the principal or new nominee. However, issues concerning actual consideration for the transfer and the taxes that may be due may arise. Moreover, the relevant laws and regulation provide that before registering a transfer of share to the new shareholder, the corporation’s corporate secretary must satisfy itself that proper taxes have been paid to the Bureau of Internal Revenue (BIR). This is done by the submission of the tax returns and the tax clearance or certificate of authority to register issued by the BIR.

In terms of taxation, currently, the sale of shares of stock is subject to a flat rate of 15 percent on capital gains taxes (CGT). There is also the Documentary Stamp Tax (DST) which is P1.50 for every P200 on the sale or transfers of shares of stocks. It also used to be the practice of the BIR examiners to assess Donor’s Tax on the transaction when the declared consideration for the transfer of shares was below the book or market value.

The taxes that may be imposed could be substantial, as some nominees may hold thousands of shares in their names. This practice is not prohibited nor uncommon, as the only requirement is that the shareholder and director hold at least one share of stock.

Accordingly, are these transfers of shares of stock by nominees back to their principal or to the new nominees subject to the CGT, DST, or Donor’s Taxes ?

The answer is: No.

In a tax ruling dated Nov. 8, 2021, Sun Life of Canada (Philippines), Inc. (Sun Life), requested the BIR for an exemption from the payment of taxes on the transfer of their Manila Polo Club shares.

Sun Life’s shares were registered in the name of and assigned to its officers who were allowed to make use of the facilities of the Polo Club in building their business network. It sought a transfer of the shares to a new set of officers as the previous officers were no longer connected with the company.

The company representatives all executed Declarations of Trust where they declared that Sun Life is the true and beneficial owner of the shares, that the shares were registered in their names because the articles of incorporation of the Manila Polo Club provides that no institutional members shall be admitted as a shareholder, that they have no title, right, claim or interest whatsoever over the shares, and Sun Life may designate another company officer as the new holder and user of the shares.

The BIR confirmed that:

1. The transfer of shares from the nominee-officers to the new nominee-officers were not subject to Capital Gains Taxes 2. The transfers are also not subject to the Documentary Stamp Taxes; 3. The transaction is not a Donation 4. The tax that is due is the Documentary Stamp Taxes on the Deeds of Declaration of Trust

(BIR Ruling No. OT – 0653-2020, November 8, 2021)

Sun Life’s shares of stock in the Manila Polo Club in the name of its nominees were covered by Declarations of Trust executed by the nominees all of whom acknowledged that the transfer did not give them any kind of right, claim or interest whatsoever in the shares and that they are holding only legal ownership of the same where the beneficial ownership belongs to the Company.

It was established that Sun Life was the one who purchased the shares and had registered the same in the officers’ names, who were its nominees, since the Articles of Incorporation and By-laws of the Manila Polo Club provided that only natural persons may become registered members.

Sec. 24 (C) of the National Internal Revenue Code provides that a final tax rate of fifteen percent is imposed upon the net capital gains realized during the taxable year from the sale, barter, exchange, or other disposition of shares of stock in a domestic corporation, except shares sold or disposed of through the stock exchange.

Accordingly, CGT is only imposed upon the “net capital gains” realized during the taxable year which means the tax is on gain or profit from the sale of capital assets.

Since the transfer of the Manila Polo Club shares only involves legal title and not beneficial ownership, which remains with Sun Life, then there is no gain or profit and consequently, no capital gains taxes are due.

The BIR found that no capital gains taxes are due considering that:

(1) the shares are actually owned by Sun Life, and the transferors and transferees are mere nominees and/or trustees of Sun Life who only hold legal title (2) There is no actual transfer of ownership and beneficial title (3) no monetary consideration is involved, no gain or profit resulted in the transfer which is merely by virtue of an assignment as evidenced by the Declaration of Trust.

In the matter of DST, the BIR declared that a mere transfer of a share from one trustee to another, without a change in the beneficial ownership of the share is, therefore not the taxable transaction being contemplated under the Tax Code provision on DST. There being no new conveyance to speak of in this case, there is no new exercise of a privilege upon which DST may be imposed.

DST on trust document

DST is however due on the Declaration of Trust.

Not a donation

There is a lack of any intention on the part of the transferors to donate to the transferee the Manila Polo Club shares. Moreover, the transaction was found to be purely for a legitimate business purpose. Accordingly, there is no donation and no donor’s tax due.

The BIR confirmed that in a trust relationship covered by a declaration of trust, transfers by the nominee of shares of stock held by it back to the principal or to a new a nominee is not subject to CGT and DST. It is also not a donation subject to donor’s taxes.

Lastly, just a final word on trust for our readers.

A trust is a legal relationship where one person has equitable ownership of property and another person owns the legal title to the property. Trusts are distinguished by the separation of legal title and equitable ownership of the property, with the fiduciary (trustee) holding legal title and the trustor holding equitable title. (Soledad Caezo vs. Rojas, G.R. No. 148788, November 23, 2007)

A trust may be expressed or implied. In this case, the Declaration of Trust referred to in BIR Ruling No. OT – 0653-2020 is an express trust. It is a document whereby a person acknowledges that they hold the property title for the use of another.

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(The author, Atty. John Philip C. Siao, is a practicing lawyer and founding Partner of Tiongco Siao Bello & Associates Law Offices, teaches law at the MLQU School of Law, and an Arbitrator of the Construction Industry Arbitration Commission of the Philippines. He may be contacted at [email protected] . The views expressed in this article belong to the author alone.)

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Everett Assignment

• What is an a ssignment?

What is an Everett assignment?   

What is the tax advantage of an everett assignment   .

• What about assignments dissimilar to Everet t type assignments ?     
• Allowable deductions for expenses related to assigned partnership interests
• Assigning a prospective interest in a partnership
• Assignments causing dissolution of the partnership

Deed of assign ment with clause enabling revocation   

What is an a ssignment   .

An assignment involves an entity or individual (the assignor) transferring contractual rights and benefits to another entity or individual (the assignee).   

For example, assume John enters into a contract with David. Under the contract, John must perform services for David and is then entitled to a payment of $10,000. However, John assigns his right to receive payment to Jared. Therefore, Jared is entitled to be paid the $10,000 fee for services performed by John.   

Although the assignment transfers the contractual benefits to the assignee, generally, the assignor is not permitted to transfer obligations under the contract to the assignee.    

An Everett assignment is a reference to the type of assignment that the High Court considered in the Everett case of 1980. The case involved a taxpayer who was a partner in a legal firm that operated through a partnership structure. The taxpayer assigned part of his interest in the partnership to his spouse. The taxpayer claimed that the partial assignment of his interest was effective to shift the burden of tax to the assignee (his spouse) in respect of that part of his interest assigned. The Commissioner of Taxation argued to the contrary. The court agreed with the taxpayer and confirmed that if a partner assigns their interest in the partnership to another, the net income of the partnership attributable to that assigned interest is considered to have been derived by the assignee (not the assignor). That is, the assignee is the relevant party assessed in respect of that assigned partnership interest.   

It was confirmed that a partner’s interest in a partnership is a chose in action which may be effectively assigned at law. This is because the partnership interest itself inherently carries a right to a proportion of partnership profits, subject to the terms of the partnership agreement. The assignment of that partnership interest itself confers on the assignee the right to receive profits on the interest. The assignee should therefore be assessed.   

Note that an assignment does not pass on rights to the assignee to be involved in the business affairs of the partnership in the same ways as the assignor. Therefore, the assignment of the partner’s interest can occur without the concern of the assignee being issued with partnership rights.   

The endorsement of Everett assignments is significant. The primary tax advantage is that a partner can effectively organise for partnership profits to be assessed to someone else (the assignee) who has a lower marginal tax rate . Commonly, this would be a spouse or relative of the assignor partner. Because the assignee has a lower personal tax rate, the profits attributable to the partnership interest are subjected to a lower rate of tax.   

As an example, take James who is a partner in a partnership and who has taxable income (not including partnership income) of $180,000. In 2023-24, the applicable tax outcome (assuming no deductions or offsets) is $51,667. Any further taxable income will be subject to tax at 45c for each $1. However, James’ spouse, Ella, has taxable income of $45,000. In 2023-24, the applicable tax outcome (assuming no deductions or offsets) is $5,092. Any further taxable income from will be subject to tax at 32.5c for each $1 up to $120,000 and then 37c per for each $1 up to $180,000, etc.   

In this scenario, it is preferrable for Ella to receive any further assessable income (that will increase her taxable income) as that assessable income would be subject to lower rates of tax.   

For instance, if James derived assessable partnership income of $10,000, he would have a tax liability of $4,500. However, if Ella derived the same amount, she would only have a tax liability of $3,250. Therefore, the overall tax result is $1,250 saved.   

The Everett principle allows this to occur by enabling James to assign his partnership interest to Ella. Although Ella is taxed on the assigned partnership interest she does not obtain partnership rights e.g. the right to participate in business decisions. James continues to hold full rights associated with the assigned partnership interest.    

CGT on the assignment of a partnership interest

The ATO view expressed in IT 2540 is that the assignment of the partnership interest or part of a partners interest triggers CGT event A1 for the assignor and as it is treated as the disposal or partial disposal of a CGT asset, being the partnership interest. Although note that technically the partnership interest is not disposed. Instead, there is an equitable interest created in respect of the partnership interest.   

A capital gain is calculated as capital proceeds less the cost base of the CGT asset.   

The capital proceeds from the CGT event will usually be based on the market value of the partnership interest assigned. This is because the market value substitution rule applies where the CGT event does not involve an arm’s length dealing.   

The cost base of the CGT asset will include the amount the assignor partner paid to acquire the partnership interest.   

The 50% CGT discount may be available if the partnership interest is held by the partner assignor for at least 12 months before the date of assignment (and other criteria are met).   

Small business CGT concessions

The small business CGT concessions may be available to a partner assignor in respect of the assignment of a partnership interest.   

There are a number of complex criteria for the partner to be eligible. These criteria are not addressed in this article.   

What about assignments dissimilar to Everet t type assignments ?   

Galland type assignments  

After the Everett decision, there was some uncertainty about whether a share in a partnership interest could be effectively assigned (and taxed) to a discretionary trust , particularly where the assignor was also a beneficiary or appointor of the trust and/or a trustee or a director of a corporate trustee.    

The court in the Galland case addressed this uncertainty and confirmed:   

• That an assignment to a discretionary trust was effective to pass assessment to the trustee assignee, even where the assignor was a beneficiary, appointor, trustee of the trust, or a director of the corporate trustee.   
• That an assignment made part way through an income year would be effective to vest the partner’s share of partnership profits in the assignee for the entirety of that income year (not just the portion of the income year following the date of the assignment). For example, if a partnership interest were assigned on 29 June, the assignment would be effective to have the assignee assessed for the entire income year (1 July – 30 June) and not merely the part of the income year following 29 June.   

Assigned partnership Interest of retiring partner  

The assignment of a partnership interest by a retiring or resigning partner may not be effective. This is because the retiring / resigning partner only has a right to a share in partnership profits whilst they remain in the partnership. That is, the retirement / resignation of the partner marks the end of their partnership interest. Therefore, any partnership interest assignment on foot will end once the relevant assignor partner exits the partnership.   

The application of the general anti avoidance rules   

Importantly, the Everett case and the Galland case did not consider the operation of the general anti avoidance provisions (Part IVA) or the equivalent provisions operating at the time.  

Therefore, it is entirely possible that tax benefits achieved under arrangements similar to those described in Everett and Galland may be cancelled if the ATO chose to exercise its powers under Part IVA.   

The ATO approach thus far seems to steer away from scrutinising arrangements which are materially similar to Everett and Galland. However, there appears to be increasing appetite for threatening the application of Part IVA for other types of assignments or arrangements designed to allocate profits in such a way to achieve favourable tax outcomes. This is seen in the recent release of the ATO’s Practical Compliance Guideline 2021/4.   

PCG 2021/4 addresses the allocation of profits amongst individual professional practitioners within professional firms (e.g. accounting firms, legal firms etc.) The PCG has limited scope. For example, the PCG will not apply to an assignment where the assignment is:   

• Commercial driven, and    
• Not materially different from Everett and Galland, and   
• Demonstrates no high risk features as defined in the PCG.   

However, if applicable, it provides a framework for defining the risk that certain profit allocation arrangements will be reviewed by the ATO. Obviously, the higher the review risk, the more likely it is that the ATO would consider applying Part IVA.  

The following profit allocations arrangements are considered materially different from those in Everett and Galland:   

• Where non owners or non equity holders are indemnified by owners or equity partners in respect of professional liability against the partnership.   
• Admitting an individual as partner where that individual does not have equity or ownership in the partnership.   
• Where an IPP is a dressed up contractor or employee rather than a genuine partner.   
• Where an IPP has a fixed right to a salary or to draw profits without bearing risks (or sharing in benefits) related to the partnership.   
• Where an IPP does not have rights, or has limited rights, to involvement in decision making and benefits under the partnership compared with other partners.    

Allowable deductions for expenses related to assigned partnership interests   

If a partner assigns their partnership interest, they may not claim a deduction for partnership interest related expenses incurred. This could include interest payments in respect of a borrowing to acquire the partnership interest.   

However, outgoings which are not directly related to the partner’s interest itself may continue to be deductible. This could include general expenses such as the cost of self education that improves the ability of the partner to perform their services as a partner.   

If the partner assigns only part of their partnership interest, they can claim a deduction for the relevant outgoings that reflects the proportion of their total partnership interest which has not been assigned. For example, if a partner assigns half of their interest in the partnership, the partner can claim a deduction for half of expenses related to their partnership interest.   

Assigning a prospective interest in a partnership   

If a partner assigns a prospective interest in a partnership (referred to as a pre admission Everett assignment), as opposed to an subsisting partnership interest (similar to a basic Everett assignment), it is likely that CGT event D1 or E9 will occur.    

A pre admission Everett assignment involves a person who is yet to be admitted as partner agreeing to assign their future partnership interest. In this situation, on admission of the partner to the partnership, a trust is established of which the assignor partner is the trustee. The trust property is the assigned partnership interest over which the assignee obtains a beneficial interest.   

If the assignment is made to a person other than the partner, CGT event D1 will likely occur at the time of contract.   

A capital gain under CGT event D1 is calculated as the capital proceeds from creating the right (generally the market value of the right) less incidental costs.   

If the assignment is made to the partner themselves (e.g. through a discretionary trust), CGT event E9 will likely occur at the time of agreement. Note that CGT event E9 deals with a situation where a taxpayer makes an agreement to hold future property on trust.   

A capital gain under CGT event E9 is calculated as the market value of the trust property (i.e. the assigned partnership interest) less incidental costs. The market value of the assigned interest is determined at the time the agreement is made

Assignments causing dissolution of the partnership   

If the deed of assignment contains a term which enables a party to unilaterally revoke / reverse the assignment, section 102 of the Income Tax Assessment Act 1997 will usually apply and the assignment would be considered ineffective .   

See our related article on Allocation of Professional Firm Profits

Related Articles

Allocation of Professional Firm Profits

This article is general information only and does not provide advice to address your personal circumstances. To make an informed decision you should contact an appropriately qualified professional.

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Trusts, Settlements and Estates Manual

Tsem1845 - introduction to trusts: supplementary deeds: deed of assignment.

A person may accept entitlement under a trust then transfer it onto a specific trust. The transfer is by a deed of assignment. The terms of the new trust or Will may be different from those resulting from a surrender or release of the entitlement. TSEM1850 has details of deeds of surrender or release.

A deed of assignment cannot apply retrospectively. It is effective only from the date the deed is executed.

The person assigning an interest is a ‘settlor’ within Section 620(1) ITTOIA ( TSEM4120 ).

The following provisions may also apply

• Section 624 ITTOIA ( TSEM4200 )
• Section 629 ITTOIA ( TSEM4300 ).

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• Practical Law

What are the IHT and CGT implications of a remainder beneficiary assigning his reversionary interest?

Practical law resource id 3-532-8246  (approx. 4 pages).

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Sergei Tretyakov: Aspects of a Biography Recovered

Tatiana Yudenkova

The 175th anniversary last year of the birth of Sergei Mikhailovich Tretyakov (1834-1892) saw the publication of several works focused on the life and activities of this collector and patron of arts, public benefactor and community leader, who was chief of the Moscow city administration. These works not only summarized previous scholarship but also brought to light new facts, and one might think that all the accomplishments of this outstanding individual are now well known. However, even today we continue to learn about the younger Tretyakov brother, and his good deeds that remained in oblivion for more than a century. It transpires that many of the remarkable events of his life are known neither to experts nor to art aficionados. One such example is Sergei Tretyakov’s participation in an important project linking two nations, Russia and Bulgaria.

In the very centre of Bulgaria, on the southern slope of the Balkan Mountains near the highway connecting Kazanlak and Tarnovo and crossing the Shipka Pass, a Christian Orthodox church dedicated to the Birth of Christ towers majestically: its construction funded by Russian “wellwishers” 1 donations, it is a memorial to the Russian and Bulgarian soldiers killed during the Russo-Turkish war of 1877-1878. Riddled with difficulties, the building project took 25 years to complete. The ceremony of consecration of the Shipka Memorial Church, as it is usually mentioned in historical writings, took place on September 15/27, 1902’ and was timed to mark the 25th anniversary of the Battle of Shipka Pass.

On the occasion of the celebration, the site was visited by a delegation from Russia including participants of the celebrated campaign, Russian army generals, veterans of the Balkan war and a former Russian ambassador to Constantinople Count Nikolai Ignatiev, 2 who did much for the liberation of Bulgaria and the strengthening of ties between this country and Russia. In 1889 he took control of the committee for the construction of the church in the Balkans.

In September 1902 Count Ignatiev recalled the history of the church. After the end of the war he and Olga Nikolaevna Skobeleva, 3 mother of General Mikhail Skobelev, “conceived the idea to build a memorial church, where all the fallen soldiers would be prayed for in perpetuity..” 4 Skobeleva suggested to build the church near the village of Sheinovo, to save labour and cost. Count Nikolai Ignatiev and Prince Pyotr Vassilchikov, 5 successfully argued in favour of a more hilly area, near the village of Shipka. “Regrettably, from all the people who initially nurtured the idea, I am the only one to survive,” 6 said Count Ignatiev ruefully at the conclusion of his speech at the ceremony in 1902, without telling the names of his associates. Since then history books have given all credit for initiating the project and seeing it through to the end to Count Nikolai Ignatiev and Olga Skobeleva. 7

Without belittling Ignatiev’s leadership and active involvement in the undertaking, we feel obliged to point out that in the early 1880s St. Petersburg and Moscow argued over who had first proposed the idea to build such a Christian Orthodox church in the Balkans. Today identifying that pioneer seems impossible, but documents strongly suggest that the Moscow City Council — then headed by Sergei Tretyakov — has every reason to claim such credit. Without going too much into details, the history of major events can be traced.

On February 9 1880 members of the City Council held a meeting, chaired by the chief of the municipal administration Sergei Tretyakov, to discuss proposals regarding celebrations marking the 25th anniversary of Alexander II’s coronation. One of the items put to the vote by the chairman was a donation “for the construction of a church on the Sheinovo field to the amount of 50,000 rubles, to be made from the municipal residual equity”. 8

Prince Alexander Shcherbatov said that Russian people should take care of their fellow countrymen’s graves in foreign parts rather than “leave them in the charge of those for whose sake these sacrifices were made”. 9 “Moscow should live up to the moral obligation incumbent on it as the capital of Russia,” stated Dmitry Samarin, joining the debate. The obligation was to erect a Christian Orthodox church dedicated to a historical event, as “in Kazan Russia put up a church over the bones of the Russians who conquered the city; as on the Borodino field a monastery was erected over the bones of Russians who gave away their lives fighting the troops of the whole of Western Europe. In Sevastopol, too, the same was done.” 10 After a while, at a City Council meeting on September 16 1880, Sergei Tretyakov announced the launch of a fund-raising campaign for the church construction in Southern Bulgaria. He also said that the Emperor had approved, on April 25 1880, the St. Petersburg fundraising committee for the church construction at the foot of the Balkan Mountains (the Shipka Church Committee). The letter called on the two capital cities to join their efforts for the mission of building a Christian Orthodox church — an undertaking in which “Moscow has shown so much generosity”. 11 It followed from the committee’s letter that Sergei Tretyakov was elected to it as a Moscow representative who had proposed to build a church in Bulgaria.

An issue of the “Official Gazette” in 1880 ran the following note: 11.pursuant to a report of the Procurator of the Most Holy Synod about certain individuals’ desire to build a Christian Orthodox church in order to immortalize the glorious feat of our victorious troops during the past battles for the Shipka Pass and combats over the Balkan Mountains, on the Sheinovo field, it was resolved, on September 5 1879, to permit. a collection of voluntary donations in the Empire. The Committee may invite Russian and foreign nationals to join its ranks. The Committee shall elect from its members an executive commission of seven persons — chairman, deputy chairman, secretary and treasurer — to discuss current business affairs.” 12 Sergei Tretyakov was elected to this executive commission of the St. Petersburg Shipka Church Committee.

On January 22 1881 Sergei Tretyakov attended a meeting of the executive commission, its minutes recorded on a letterhead of the St. Petersburg Shipka Church Committee. A copy of the minutes is kept in the personal file of the chief of the Moscow municipal administration. 13 The assembly also worked out a strategy to be used in the future. Henceforth the Committee’s operations were to be called “joint operations of the Committee and the Moscow City Council”, 14 thus putting an end to the rivalry for leadership between Moscow and St. Petersburg. Pursuant to the Moscow City Council’s resolution, the chief of the Moscow municipal administration Sergei Tretyakov contributed to the Committee’s treasury the first significant sum — 50,000 rubles. The Committee members approved Tretyakov’s proposal “to stop keeping incoming cash in a special account at the State Bank, as has been done previously, but to buy with this money Oriental Loan securities, in order to maximize benefits”. 15

Selecting a location for the church was one of the main issues on the agenda. Valerian Melnitsky, well familiar with the area, proposed “to raise the church near the Shipka village and the big road from Kazanlak to Tarnovo”. 16 The architect Alexander Krakau believed it was necessary to visit the area and to make construction estimates directly on site; in response to this Sergei Tretyakov proposed to send one of the Committee members in order to gather all necessary information. This task was assigned to the Committee’s chair Prince Vassilchikov, who traveled to Bulgaria in 1881. Mindful of the initial plan to build a church at the heel of the peak of St. Nicholas, where the battle for the Shipka Pass was fought in August-December 1877 and where, on December 28 1877, Russian and Bulgarian troops forced a 30,000-strong Turkish army to surrender, Count Ignatiev proposed to dedicate the church “to the Birth of Christ, since major combats between the Russian and Turkish armies took place... during the Birth of Christ holiday, near the Shipka village”. 17 The Committee approved Count Ignatiev’s proposal to dedicate “the northern aisle of the church to St. Nicholas the Miracle Worker, the southern aisle, to St. Alexander Nevsky, and to place in the iconostasis an icon of the Archangel Michael”. 18 Other issues discussed at the meeting included launching a competition for the best design, the making of cost estimates, etc.

Under Great Power resolutions at the Congress of Berlin in 1878, the section of Bulgaria to the south of the Balkans remained under the Ottomans, forming a province Eastern Rumelia. This partly accounted for the difficulties facing the church construction project: Turkish authorities obstructed the efforts to buy a plot of land for the church, so the land was first purchased through Bulgarian intermediaries. 19 In 1885 Southern Bulgaria was re-incorporated within the Principality of Bulgaria, and the ground work began. However, in 1888 the work was interrupted following the severance of diplomatic ties between Russia and Bulgaria. The Committee went through a most difficult period of inactivity from 1888 through 1896. At a Committee meeting on March 7 1891 it was proposed to stop the church construction because of the lack of control over the political situation and to channel the money into other projects. And only adamant and energetic protests on the part of Count Ignatiev, who said that the Committee “does not have the right to stray away from its mission, which was determined and supported in word and deed by donors from among Russian Christian Orthodox believers”, 20 changed the power balance at the Committee, and it resolved to put the project on hold with a view to resume it under more favourable circumstances.

In 1880 the design contest was announced, in which eight architects took part. In November 1881 the first prize was awarded to academician Antony Tomishko. In 1897 construction was resumed and the architect Alexander Pomerantsev, who had worked in Sofia supervising an overhaul of the Alexander Nevsky Cathedral, stepped in. Direct oversight over the Shipka church construction was the responsibility of the architect Alexander Smirnov, who lived in Bulgaria for a while and also participated in the construction of the Alexander Nevsky Cathedral. To manufacture crosses, bells and the iconostasis, Count Ignatiev enlisted the services of the best Russian artisans — all craftsmen, brick-layers and carpenters were brought from Russia. By 1902, the church already had a home for the clergy, a seminary, a hospital, and a home for teachers.

The church is designed in 17th-century style, with a ground floor, five domes, a steeple-roofed belfry, and the exterior adorned with glazed tiles. The carved gilded iconostasis made of linden was designed by Alexander Pomerantsev, and its icons, on cypress boards, were donated to the church by craftsmen from the Russian St. Pantaleon (Panteleimon) church on Mount Athos; some icons were donations from Russia. The murals were created only in the mid-20th century. The altar crucifixes, the Gospel, holy vessels, service books, chandeliers and other church paraphernalia were bought in Russia thanks to contributions from the Committee and private persons.

A list of relics in the vestry mentions old sacerdotal robes — a gift from the Holy Trinity - St. Sergius Lavra. The belfry has 17 bells cast in Moscow, the heaviest weighing 711 poods (approximtely 11,646 kilograms); 40 bridges had to be buttressed when the bells were carried from the railway station. The crypt is home to 17 sarcophagi containing remains of the Shipka defenders. The church has open galleries flanking it to the north and south, its inner walls and outdoor vaulted galleries graced with 34 marble slabs featuring inscriptions in gold — the names of the officers and the number of Russian soldiers killed. Overall, 18,491 people are memorialized.

Now let us return to Sergei Tretyakov — was his energetic and generous involvement with the Shipka church construction a matter of chance alone? Was it a fortuity? What do we know about his views on “the Balkan question”? A handful of letters and a memoir of Nikolai Naidenov, Sergei Tretyakov’s community work associate in Moscow, give some idea about the scope of his activities before and during the initial phase of the Russo-Turkish war.

On April 4 1876 Ivan Aksakov directly approached Sergei Tretyakov as a representative of Moscow merchants and asked him to start collecting donations for assistance to refugees from Herzegovina, which was devastated by its fight for liberation from the Ottoman yoke.

In the summer of 1876, when the political situation in the Balkans deteriorated, the retired Major General Rostislav Fadeev 21 introduced a proposal to the Moscow Exchange and Merchants’ Society to start collecting money for volunteer military units in Bulgaria and the purchase of munitions for them. Then head of the merchants’ community, and with good connections among high officials in St. Petersburg, Sergei Tretyakov was given an “assignment”, as Nikolai Naidenov recalled, to check this information: “Tretyakov meanwhile... has had a chance to meet appropriate officials and received a confirmation of Fadeev’s intelligence; the collection drive was begun at the Exchange in association with the Merchants’ Society; as I remember, 200,000 rubles was collected overall, and then Aksakov took the helm...” 22 However, Sergei Tretyakov waited for ten days after the retired general’s arrival in Moscow to announce the start of the subscription (probably he needed the time to check the information).

Fadeev was disgruntled by the procrastination on the part of the Moscow merchants, who promised “huge donations for the Bulgarian cause”. In July 1876 Fadeev asked Aksakov as a person “who mixes with merchants” to explain the reasons for the delay: “Yesterday.. His Majesty for the first time expressed his full approval of our undertaking: he said: ‘I expect a lot from this sort of community action, just hoping it will continue to be public [italicized by Fadeev — T.Y.] without betraying its governmental sponsorship’. His Majesty knows that the donations are earmarked for guns for the Bulgarians; he has been told the names of the founders of the patriotic movement: Tretyakov, Morozov, Naidenov. 23 ” A researcher of the Slavic Committees Sergei Nikitin, talking about the activities of that special Bulgarian commission, quoted what one of its members, General Nikolai Stoletov, said about the three Moscow merchants mentioned: “The persons administering the mentioned preparations come from the ranks of foremost Moscow capitalists and do not pursue any commercial gains in the course thereof. 24 ” At about the same time, in August of the same year Sergei Tretyakov, in a letter to his brother (August 24 1876), talked about his deep sorrow for what has happened: “To the utmost regret, the Serbian affairs have taken the nastiest possible turn. I am to meet General Ignatiev this evening. and very interested to learn his views about the current state of affairs. 25 ”

With the war just started, the Tsar and his ministers already had an official agreement with the “Bulgarian commission” about the manufacturing of uniforms and equipment for the Bulgarian militia (according to Minister of War Dmitry Milyutin’s letter to Ivan Aksakov of April 28 1877). 26 The commission was formed at the end of 1876 and included Moscow industrialists and merchants such as Pompei Batyushkov, Timofei Morozov, Sergei Tretyakov, Nikolai Naidenov, Vasily Aksenov. It follows from the letter that the first shipment of equipment (still prior to the start of the war) had already been sent to Bulgaria; the letter also goes over such questions as the need for a second shipment and settling accounts with the Muscovites. Naidenov in his memoir told about further actions of the Bulgarian commission: “The activities of our little club in charge of providing the Bulgarian fighters with uniforms... continued; the following participated from the start to the end: Sergei Tretyakov [topping the list — T.Y. ], V.Aksenov, P.Sanin, TMorozov and I”. 27 The merchants from Moscow also had to provide footwear for the Bulgarian militia: “.it was told then that when our army supply officers saw our footwear, they took it away from the Bulgarians, giving them instead shoes of the kind regularly supplied for the Russian army, which were complete rubbish compared to the footwear we provided.” 28 Thus, the letters tell us about Sergei Tretyakov’s committed and energetic work which bespeaks, above all, his vigorous involvement with politics and public affairs at that period — it was not a co-incidence that he was soon elected chief of the Moscow municipal administration (all candidates for the office had to be approved by the Tsar); the letters also show that he was close to the Moscow Slavophiles.

One of Pavel Tretyakov’s daughters wrote in her memoir that the Tretyakov brothers in the 1860s kept close contacts with the Slavophiles. “At that time, our home was frequented by Slavophiles: the Cherkasskys, the Baranovs, the Shcherbatovs, the Aksakovs, the Stankevichs, the Samarins and the Chicherins. Pavel Mikhailovich had personal relationships with them centered around politics, social issues and municipal community activities. Yury Fedorovich Samarin visited especially often.” 29 In the same period, the 1860s, Yury Samarin and Sergei Tretyakov worked together at commissions of the Moscow City Council: Tretyakov was an overseer of the Yakimanskaya neighbourhood, and Samarin was his assistant. 30

The archive of the head of the Moscow City Council has several letters that, at first glance, do not seem to have an obvious connection with the said official’s competence: representatives of the Czech community asked Tretyakov to help in resuscitating the Christian Orthodox faith in the Czech land. 31 ; Other documents in the file show that at the meetings of the Council the chief of the Moscow municipal administration often announced donor campaigns for building churches in the far corners of the Russian empire. Tretyakov’s name topped the subscription list for the construction of a brick Christian Orthodox church dedicated to St. Nicholas the Miracle Worker in the city of Brest; it was the response to a request of the Brest-Litovsky Christian Orthodox fraternity of St. Nicholas. 32 His archive contains letters with requests for financial assistance to Russian and Polish Christian Orthodox communities, 33 and for donations to purchase church plates for rural churches in the Kingdom of Poland. 34 There are also receipts showing that Tretyakov personally financed a purchase of icons in silver cases and sent them to Bulgaria. 35

Did the pleaders address Sergei Tretyakov as the chief of the Moscow municipal administration, or as a member of the Slavic Charitable Committee? It is presently known that Tretyakov participated in the organization of festivities in Moscow in honour of guests from Slavic nations at an Ethnography Exhibition in 1867; Tretyakov then was a member of a Moscow committee in charge of the reception of scholars from Slavic nations. Other committee members included Yury Samarin, Mikhail Pogodin, Vasily Kokorev, Timofei Morozov, Fyodor Rezanov, and Vladimir Vishnyakov. Sergei Tretyakov took charge of organizational and financial matters: meeting the guests and placing them in private homes, making provisions for dinner parties and so on. 36 Perhaps it was at that time that Slavic community leaders appreciated Tretyakov as a person always willing to respond to their needs. Although lists of the Moscow Slavic Committee members have yet to be found, it is known that the Tretyakov brothers frequently made monetary contributions to the Moscow Slavic Society, according to Pavel Tretyakov’s records of expenditures, the contributions were made annually, beginning from 1876. On April 14 1880 they received an acknowledgement from Ivan Aksakov for a new financial contribution.

Further research into the biographies of the Tretyakov Gallery’s founders is bound to uncover facts virtually lost in the public memory which directly link the brothers to the historical fortunes of Russia of that era and, accordingly, expand the boundaries of what we know both about the period and the individuals concerned.

• At the same period the Most Holy Synod issued a directive that Russian monks should provide spiritual guidance for the Shipka monastery. The memorial church was Russian property; in 1934 it was transferred to Bulgaria. First managed by the Synod of the Bulgarian Orthodox Church, the church compound was then transferred to the Ministry of Defence, and later, to the Ministry of Culture. In 2003 the church was renovated by the Baltic Construction Company from Russia. In 2004 the memorial church became the property of the Bulgarian Orthodox Church again.
• Nikolai Ignatiev (1832-1908) was a Russian diplomat, General of Infantry in 1878. He concluded the Treaty of Beijing between China and Russia in 1860 and headed the Asian Department of the Ministry of Foreign Affairs in 1861-1864, and in 1864-1877 served as the Russian ambassador to Constantinople. From February through March in 1878 he was the head of the Russian delegation in San Stefano when the peace treaty between Russia and the Ottomans was signed; later Ignatiev was Russia's envoy at the Congress of Berlin (1878).
• Olga Nikolaevna Skobeleva (1823-1880), nee Poltavtseva, oversaw military hospitals during the Russo-Turkish War of 1877-1878. After the death of her husband General Dmitry Skobelev in 1879 she traveled to the Balkan Peninsula, where she worked as the head of the Bulgarian Red Cross. She was brutally murdered in Bulgaria on July 6 1880.
• “Shipka celebration - A chronicle". Newsletter of St. Petersburg Slavic Charitable Society [Izvestia Sankt-Peterburgskogo Slavyanskogo blagotvoritelnogo obshchestva]. St. Petersburg, 1902. No. 2. P. 28.
• Pyotr Alexeevich Vassilchikov (1829-1898) was an officer of the provincial government in St. Petersburg. He chaired the Shipka Church Committee from 1880 to 1889.
• “Shipka celebration - A chronicle". P. 28.
• Andrei Ignatiev. “Memorial Church at the Shipka Pass". Magazine of Moscow Patriarchate. 1960. No. 10. P. 56. Marinka Gocheva, Pencho Sinkov, Dancho Danchev. National Park Museum Shipka-Buzludzha. Sofia. 1986. P. 28 (translated from Bulgarian by Ye. Denisieva). Ivan Khristov, Slavi Todorov. Shipka. A guide-book. Sofia. 1987. P. 68. Ivan Khristov. Shipka landmarks. A guide-book. Sofia. 1987. P. 60. Victoria Khevrolina. Nikolai Pavlovich Ignatiev. The Russian diplomat. Moscow, 2009. P. 347.
• Newsletter of Moscow City Council. February 9 1880. Moscow, 1880. Issue IX. P. 133.
• Ibid. P. 136.
• Ibid. P. 137.
• Newsletter of Moscow City Council. September 16 1880. Moscow, 1881. Issue III. P. 532.
• Official gazette. 1880. 12th of June.
• Department of Printed and Written Sources of State Historical Museum. Fund 169, item 6, sheet 31.
• Department of Printed and Written Sources of State Historical Museum. Fund 169, item 6, sheet 31 (reverse side).
• Department of Printed and Written Sources of the State Historical Museum. Fund 169, item 6, sheet 32.
• “In 1885 a purchase deed for a plot of land was nominally made in the name of a Kazanlak resident, who later transferred the ownership to the Committee's chair Pyotr Vassilchikov” (Quoted from: Andrei Ignatiev. Op.cit. P. 56).
• Quoted from the article “Archimandrite Kirill, Father Superior of the Bulgarian town church in Moscow” // Magazine of Moscow Patriarchate. 1982. № 12. P. 111.
• Rostislav Andreevich Fadeev (1824-1883) was a retired Major General, military writer and commentator. He was against the military reforms of Dmitry Milutin. Fadeev supported Pan-Slavism and was a member of the St. Petersburg Slavic Committee from 1870. In 1876-1878 he participated as a volunteer in the national emancipation struggle of the Balkan peoples.
• Nikolai Naidenov. Memoirs about Things Seen, Heard and Lived. Moscow, 2007. P. 254.
• Liberation of Bulgaria from Ottoman rule. Documents - three volumes. Vol. 1. Moscow. 1961. P. 300 (in Russian)
• Sergei Nikitin. The Slavic Committees in Russia, 18561876. Moscow. 1960. P. 341.
• Department of Manuscripts of the State Tretyakov Gallery. Fund 1, item 3654.
• Liberation of Bulgaria from Ottoman rule. Documents - three volumes. Moscow. 1964. Vol. 2. P. 58.
• Nikolai Naidenov. Memoirs about Things Seen, Heard and Lived. Moscow. 2007. P. 256.
• Ibid. P.255.
• Vera Ziloti. In the Home of Pavel Tretyakov. Moscow, 1998. P. 49.
• In 1866 both were members of an Anti-Cholera Committee of the Moscow City Council: Department of Printed and Written Sources of the State Historical Museum. Fund 169, item 4, sheets 31, 33, 54, 55, 68.
• The letter is dated November 4 1878, i.e. after the end of the Balkan war: Letter of November 4 1878: Department of Printed and Written Sources of the State Historical Museum. Fund 169, item 5, sheet 93.
• “Meeting of the Moscow City Council on September 10 1880". Newsletter of Moscow City Council. 1881. Issue III. P. 597
• Request for financial help to Christian Orthodox Russians and Poles, from the Council of St. Nicholas church fraternity of the city of Zamostie in the Lyublino province in the Kingdom of Poland, near Galicia: Letter of September 8 1880 // Department of Printed and Written Sources of the State Historical Museum. Fund 169, item 5, sheet 94.
• Department of Printed and Written Sources of the State Historical Museum. Fund 169, item 5, sheet 99.
• Department of Printed and Written Sources of the State Historical Museum. Fund 169, item 6, sheet 29 (obverse and reverse).
• Department of Printed and Written Sources of the State Historical Museum. Fund 169, item 2, sheets 85-98.
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