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HMRC internal manual

Capital Gains Manual

Restrictions: capital losses: time-apportionment: pooled assets

The time-apportionment formula applies separately to each tranche of expenditure on the asset disposed of, or treated as disposed of. For each tranche of expenditure, time-apportionment runs from `the relevant pre-entry date’. This is the later of

  • the date the expenditure is treated as incurred under TCGA92/S54
  • 1 April 1982.

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.