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HMRC internal manual

Capital Gains Manual

Restrictions: pre-entry loss: alternative MV calculation: part-disposals

An election only affects the pre-entry proportion of the allowable loss on the disposal to which the election relates. In the case of part-disposals of a single asset (including a pooled asset) a separate election has to be made in respect of each part- disposal. In a sequence of part-disposals there may therefore be some to which the market value rule applies, and others to which time-apportionment applies.

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.