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HMRC internal manual

Capital Gains Manual

Companies and Groups of Companies: Groups of companies: Particular Aspects: loss restriction by reference to capital allowances

TCGA92/S174 (1) - (3)

The capital gains code does not in general make a distinction between assets qualifying for capital allowances and other assets. This is subject to the following special rules.

  • The exemption for tangible moveable property which is a wasting asset does not apply to assets qualifying for capital allowances, see CG15440.
  • The expenditure restrictions for wasting assets do not apply to assets qualifying for capital allowances, see CG15445.
  • The exemption for chattels sold for £6,000 or less, see CG76573, or the exemption for passenger vehicles, see CG12619, may apply.

If an asset qualifying for capital allowances gives rise to a loss on disposal the expenditure on the asset could, in the absence of a further restriction, effectively be relieved twice. The expenditure obtains relief under the relevant capital allowances code, subject to any balancing adjustment on the disposal of the asset. And if none of the capital gains exemptions applies there would be an allowable loss for capital gains purposes. There is a similar problem where expenditure qualifies for a renewals allowance.