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HMRC internal manual

Capital Gains Manual

Groups: rebasing: elections out of kink test: time limit: subsidiary co

Although an election can only be made by the principal company of a group, the first relevant disposal which determines the statutory time limit may have been made by a subsidiary company or by an incoming company. There can accordingly be cases where the first relevant disposal is made by a company whose accounting periods do not coincide with those of the company making the election. In this situation the time limit for the election is two years from the end of the accounting period of the company making the first relevant disposal in which that disposal is made.