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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Restrictions: capital losses: outline summary: pooled assets

There are special rules applying the time-apportionment formula to pooled assets. A disposal out of a pool is identified with post-entry assets in priority to pre-entry assets. And where a disposal bites into the pre-entry part of a pool, disposals are matched with acquisitions on a first in/first out basis. Time-apportionment then applies to the cost of acquisition of the individual assets identified with the disposal. See CG47640+.

Note: Additional rules relating to loss buying were enacted in FA 2006. See CG47020+ for guidance on the rules which apply in priority to TCGA92/SCH7A for accounting periods ending on or after 5 December 2005.

FA11/S46 and FA11/SCH11 greatly simplified the rules in TCGA92/SCH7A for the deduction of losses on or after 19 July 2011. See CG47400+ for guidance on loss streaming from that date.