ETMD: the effect of section 140F
The effect of TCGA 1992 section 140F is exactly the same as that for section 140C. Separate capital gains computations are required for each chargeable asset that is transferred. Those with gains are aggregated and a separate aggregation takes place for those with allowable losses. The losses are set against the gains and if the net result is a gain then that is treated as a single chargeable gain and actual double taxation relief or notional double taxation relief will be allowed against the tax chargeable, section 140F(3). See CG45715 for a fuller explanation.