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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Deferred consideration: unascertainable: election for treatment of loss - basic requirements


A person, “the taxpayer”, is entitled to elect for an allowable loss, “the relevant loss”, which would otherwise accrue to him in one tax year, “the year of the loss”, to be treated as accruing to him in an earlier tax year if certain requirements are met.

The loss must accrue on a disposal by the taxpayer of a right which meets five specified conditions, see CG15084.

The taxpayer must be within the charge to CGT for the year of the loss, see CG15088.

Two further specified conditions must both be met, referred to in TCGA92/S279A as “Condition 1” and “Condition 2” respectively, see CG15085 and CG15086.