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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Schedule 4C pool created before 6 April 2008

FA08/Sch07/paras152 to 154

The rules described in CG39280 apply to Schedule 4C pools created on or after 6 April 2008. FA 2008 changed the matching rules in TCGA92/Sch4C in a similar way to the changes to TCGA92/S87. A Schedule 4C pool created before 6 April 2008 is dealt with under Schedule 4C as it applied before the FA 2008 changes. Trust gains accruing after 5 April 2008 cannot be added to a pre-6 April 2008 Schedule 4C pool.

If the trustees do have a Schedule 4C pool created before 6 April 2008 capital payments received after 5 April 2008 are matched in the following order:

  • against gains in a Schedule 4C pool created after 5 April 2008
  • against gains in a Schedule 4C pool created before 6 April 2008
  • against section 2(2) amounts not in a Schedule 4C pool.

Capital payments matched against gains in a Schedule 4C pool created before 6 April 2008 are matched against the gains of earlier years first. In other words the pre-FA 2008 first in first out basis continues to apply. This will be relevant when calculating any increase in the rate of tax charged, TCGA92/Sch4C/para13.