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HMRC internal manual

Capital Gains Manual

Restrictions: pre-entry loss: alternative MV calculation: pooled assets

These additional rules apply where there is a market value election on a disposal (`the real disposal’) of the whole or any part of a pooled asset, and apart from the election the time-apportionment rules for pooled assets in paragraph 3 Schedule 7A would apply. You first compute the loss that would have arisen on a disposal at the relevant time of all the assets to which the rules apply. You then apportion the loss between the assets to which the real disposal is treated as relating and the other assets in the notional disposal, by reference to the numbers of assets involved. If the assets covered by the notional disposal rules have different relevant times, there is a different notional disposal at each of those times.

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.