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HMRC internal manual

Capital Gains Manual

Years before 2008-09 - unmatched capital payments


If there is a surplus of capital payments over trustees’ gains for years before 2008-09 it is necessary to identify the year in which the capital payment was received. For years before 2008-09 capital payments that were matched against trustees’ gains were reduced by s87(6) in its original form. This was repealed when FA08 introduced the new matching rules but FA08/Sch07/para122 preserves its effect to establish the starting position in 2008-09. The ordinary matching rules in s87A will then apply to the earlier years.

All of a capital payment matched before 2008-09

If all the capital payments were matched in earlier years they are simply reduced to nil, FA08/Sch07/para122(1), example CG38750.

Only part of a capital payment matched before 2008-09

If only part of a capital payment was matched the payment is reduced by that part, FA08/Sch07/para122(2), example CG38750.

More than one capital payment matched before 2008-09

If capital payments for more than one year were matched but the total capital payments were greater than the trustees’ gains you identify the part of unmatched capital payment on a first in - first out basis, FA08/Sch07/para122(3), example CG38755.