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HMRC internal manual

Capital Gains Manual

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

If an outgoing company made the first disposal in the group to which Section 35 applies, that disposal is disregarded in determining the group’s first relevant disposal. This is the result of TCGA92/SCH3/PARA8 (5)(a).