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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Deferred consideration: shares/securities: notifications made prior to royal assent

FA97/S89 (6)

Unless otherwise directed by the Board a notification given either

  • in anticipation of the right to elect under TCGA92/S138A, or
  • as a claim under ESC/D27

shall be treated as a valid and irrevocable election. This allows taxpayers to elect in the period between the withdrawal of the concession and the day when FA97 received Royal Assent. It also covers those open cases where the taxpayer claimed under ESC/D27 before 26 November 1996 and gives the treatment that results from an election under TCGA92/S138A.