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HMRC internal manual

Capital Gains Manual

Restrictions: capital losses: time-apportionment: pooled assets

TCGA92/SCH7A/PARA3 (9)

In applying the time-apportionment formula to the disposal of a pooled asset, it may be necessary to apportion acquisition expenditure, incidental costs, or consideration received between the notionally separate asset and other assets acquired or disposed of at the same time. You should make any such apportionment on a pro rata basis by reference to the number of individual assets included in the notionally separate asset and the number of the other individual assets of the same class acquired or disposed of at the same time.

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.