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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Groups: rebasing: elections out of kink test: 1st disposal

The general rule is that the first disposal to which Section 35 applies, and which is made by any company in the group, is the first relevant disposal for the group as a whole. This disposal establishes the time limit for the election by the principal company. There are special rules for disposals by outgoing companies and incoming companies.