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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Groups: rebasing: deferred charges


The result of the various provisions which roll over or postpone gains may be that an event on or after 6 April 1988 would trigger a tax charge on a gain accrued before 31 March 1982 in circumstances where the general rule rebasing gains and losses to 31 March 1982 gives no effective restriction. The rebasing legislation accordingly includes special provisions in TCGA92/SCH4 which in certain circumstances either halve a deferred tax charge or eliminate it completely. In relation to companies, the provisions affected include

  • TCGA92/S116 (acquisition of qualifying corporate bonds on a reorganisation of share capital including a share exchange, see CG53709+)
  • TCGA92/S140 (outward domestication, see CG45660+)
  • TCGA92/S152 (roll-over relief on replacement of business assets, see CG60250+)
  • TCGA92/S154 (depreciating asset acquired as replacement for business asset, see CG60370+)
  • TCGA92/S178 and TCGA92/S179 (degrouping charges, see CG45400+).

The provisions which halve or eliminate deferred charges only apply if there is a claim. Further instructions are at CG16980+.