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HMRC internal manual

Capital Gains Manual

FA08/Sch7/para126 and section 13 losses - example

The facts are the same as in CG38880 except that the 6 April 2008 value of the assets sold by Y Ltd is £1.4m. This produces a loss of £200,000 by reference to the 6 April 2008 value (£1.2m - £1.4m). The appropriate proportion of this loss is £150,000 but it cannot be attributed to the trustees.

The relevant proportion of beneficiary B’s £100,000 section 87 gain is calculated by reference to the rebased value of the assets sold by the trustees and the £80,000 gain on the disposal of Y Ltd’s assets which are not relevant assets.

£100,000 x (£40,000 + £80,000) = £23,076