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HMRC internal manual

Capital Gains Manual

Deferred consideration: unascertainable: election for treatment of loss - first year limit


Where the first year is 2008-09 or a later year, the first year limit is the amount calculated under section 2(2) read in conjunction with section 2(4A).

For the purposes of this calculation no account is taken of the loss for which the election has been made but the effect of any previous election under section 279A must be taken into account.

Where the first year is 2007-08 or an earlier year the computation of the first year limit is different and is more complicated where there are gains attributed under Sections 77 or 86. You should consider the statute applicable for that year which details the steps of the computation that should be made. Cases of doubt or difficulty the case can be referred to Capital Gains Technical Group.