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HMRC internal manual

Capital Gains Manual

Repudiation of concessions which defer capital gains charges: Background

TCGA92/S284A & TCGA92/S284B

Various capital gains concessions have the effect of deferring a tax charge. For example, a taxpayer may take advantage of ESC/D22 to claim roll-over relief when it is not strictly due, see CG60410. Or the taxpayer may use paragraph 10 of ESC/D33 to defer a gain under TCGA92/S23, see CG12985, CG13020 and CG15700+.

Concessions like these have a knock-on effect. In the examples above

  • the relief reduces the allowable base cost of the relevant asset
  • the gain on a later disposal of that asset is greater than it would otherwise have been because of the previous concessional relief.