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HMRC internal manual

Capital Gains Manual

Capital allowances: deemed disposals and reacquisitions

Certain provisions treat the owner of an asset as having disposed of and reacquired that asset at market value at a given date. As a consequence the reacquisition cost is not expenditure in respect of which a capital allowance or renewals allowance is made, and so TCGA92/S47 would not operate as intended without specific provision. The following

  • TCGA92/SCH3/PARA3 for the purpose of rebasing to 31 March 1982, see CG16900
  • TCGA92/S55 (3) for the purpose of computing indexation by reference to market value at 31 March 1982, see CG17450
  • TCGA92/SCH2/PARA20 for the purpose of assets held at 6 April 1965, see CG15510

provide that Section 47 shall apply in relation to capital allowances or renewals allowance made in respect of the expenditure incurred as if it were made in respect of the expenditure deemed to have been incurred reacquiring the asset.