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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Deferred consideration: shares and securities: transitional provisions

FA97/S89

At CG58029 you were told that before the introduction of TCGA92/S138A a vendor could claim under ESC/D27 and that the computational consequences of a claim under the ESC were the same as they are following an election under the legislation. The transitional provisions in FA97/S89 ensure a seamless transition from one regime to the other.