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HMRC internal manual

Capital Gains Manual

Capital allowances: asset acquired at capital allowance written down value

TCGA92/S41 (3)

If the person making the disposal acquired the asset at its capital allowances written down value
 

  • by a transfer by way of a sale in relation to which an election under CAA01/S569 was made (sales without change of control or between connected persons), or
  • by a transfer to which CAA01/S268 applies (succession to trade on death)

any adjustment of the loss accruing to the transferee is to take account of any capital allowances made to both the transferor (including previous transferors) and the transferee. A similar restriction of the capital gains loss should be made where
 

  • CAA01/S264 (3) (partnership using property of a partner),

or

  • CAA01/S558 (succession to trades, etc) have been applied.