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HMRC internal manual

Capital Gains Manual

Assets held on 6/4/65: election for valuation on 6/4/65 irrevocable

TCGA92/SCH2/PARA17The purpose of the time-apportionment formula, see CG15570, is to avoid the work which would be involved in the valuation of all assets on 6 April 1965. In some circumstances this formula is inequitable and so the owner of an asset to which the time-apportionment formula applies may elect for an actual valuation on 6 April 1965 instead. The owner is then assessed on the actual gain which accrues from that date. The market value is introduced by deeming the asset to be sold and immediately reacquired at market value on 6 April 1965. An election for the valuation of an asset on 6 April 1965 is IRREVOCABLE.