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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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TCGA92/Sch4B - 'proceeds' of trustee borrowing

TCGA92/Sch4B/para4(2)

The amount of the trustee borrowing is called the ‘proceeds’ of the borrowing:

  • If the trustee borrowing is a loan the proceeds are the market value of the asset lent. The market value of sterling is its amount, TCGA92/Sch4B/para13(1).
  • If the trustee borrowing is the transfer of an asset the proceeds are the market value of the asset reduced by the amount or value of any consideration received for it.

You assess the market value immediately before the loan is made or the transfer is effectively completed unless the asset is created by the loan or transfer. In that case you take the value immediately after the time of the borrowing, TCGA92/Sch4B/para4(3).