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HMRC internal manual

Capital Gains Manual

Restrictions: alternative market value calculation: disposals 30/11/93p

For disposals on or after 30 November 1993, the extent to which indexation allowance can create or increase a loss is subject to restrictions, see CG17700+. Without special rules, in a situation where the actual disposal took place on or after 30 November 1993, but the market value calculation would be by reference to a date before 30 November 1993, the benefit of a market value election could be reduced, or removed. This is because the indexation component of the loss would be restricted in relation to the calculation of the pre-entry proportion of the loss on the time-apportionment basis, but would not be restricted in relation to the market value calculation at the earlier date.

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.