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HMRC internal manual

Capital Gains Manual

Groups: rebasing: elections out of kink test: 1st disposal

The reference in Section 35(6) to the first relevant disposal includes the first disposal to which Section 35 applies which is made by an incoming company. This is the result of TCGA92/SCH3/PARA8 (5)(b). In effect an incoming company is treated as though it were a member of the group at the time it made its first disposal to which Section 35 applies.