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.