CG38725 - Matching in a later year - more than one year - example - the rules for 2008-09 to 2017-18
2013-14
| Description | Amount |
|---|---|
| Trustees’ section 2(2) amount | £60,000 |
| Capital payments beneficiary A | £20,000 |
2012-13
| Description | Amount |
|---|---|
| Trustees’ section 2(2) amount | £nil |
| Capital payments beneficiary D | £30,000 |
2011-12
| Description | Amount |
|---|---|
| Trustees’ section 2(2) amount | £nil |
| Capital payments beneficiary E | £25,000 |
This example illustrates the principle that capital payments are matched taking the latest year first.
Section 87 gains
The £60,000 section 2(2) amount in 2013-14 is matched first against A’s 2013-14 capital payment of £20,000, then against D’s 2012-13 capital payment of £30,000 and finally against £10,000 of E’s 2011-12 capital payment of £25,000 leaving E with unmatched capital payments of £15,000 in 2011-14.
The gains of £20,000, £30,000 and £10,000 all accrue in 2013-14. In practice it is unusual for capital payments to be made before the gains accrue to the trustees.