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HMRC internal manual

Capital Gains Manual

Groups: rebasing: elections out of kink test: late elections

The Board have discretion to extend the time limit for making an election, see CG16780. The Area Director Compliance or the Band B Compliance Team Leader in an Area Office may accept a late election if

  • the delay in making the election results from events outside the taxpayer’s control or any other reasonable cause, and
  • the election is made within twelve months of the statutory time limit.

The Area Director Compliance or the Band B Compliance Team Leader in an Area Office may also accept a late election if the reason for the delay in making the election is that the group did not appreciate the statutory time limit runs from the end of the accounting period of the company making the first relevant disposal. In such a case the late election must be made within two years of the end of the accounting period of the principal company in which the first relevant disposal is made by another group company with a different accounting date.