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HMRC internal manual

Capital Gains Manual

Groups: rebasing: elections out of kink test: relevant time

`The relevant time’ is defined by TCGA92/SCH3/PARA9 (1) as the earliest of the following

  • the first time any company in the group other than an `outgoing company’ makes a disposal to which Section 35 applies
  • the time immediately after an `incoming company’ first joins the group
  • the time when the principal company makes an election.The first of these events is the one which is most likely in practice. The third event will apply to companies which have taken the opportunity to make an election at any time before 6 April 1990.