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HMRC internal manual

Capital Gains Manual

Deemed disposal - defined terms


The deemed disposal fractions in TCGA92/Sch4B/para11 use a number of defined terms.

VT = amount of value transferred

VT is defined in TCGA92/Sch4B/para2 for each of the three types of transfer of value, CG39115.

  • A loan is the market value of the loan. The market value of sterling is its amount.
  • A transfer is the market value of the asset reduced by any consideration received unless any part of the value of the asset is attributable to trustee borrowing, CG39205.
  • A security is the value of the security reduced by any consideration received.

EV = effective value of remaining chargeable assets

EV is the aggregate market value of those assets immediately after the transfer as reduced by any amount of that value which is attributable to trustee borrowing, CG39205.

TB = outstanding trustee borrowing

TB is defined in TCGA92/Sch4B/para5, CG39140. Money borrowed before 21 March 2001 may still be outstanding trust borrowing.

Remaining chargeable assets

‘The remaining chargeable assets’ are defined in TCGA92/Sch4B/para10(1)(b). They are the chargeable assets remaining in the settlement immediately after the material time; in other words immediately after the transfer of value. An asset is a chargeable asset if a gain on the disposal of the asset would be a chargeable gain.