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HMRC internal manual

Capital Gains Manual

Leases: capital loss arising on grant of short lease: restriction

TCGA92/SCH8/PARA6 (1)

Where

  • a short lease is granted out of a short lease;
  • a capital loss arises; and
  • the holder of the original lease is entitled to relief under ITTOIA05/S292 or CTA09/S232, see PIM2320,

the allowable loss is restricted by the amount of the relief given under ITTOIA05/S292 or CTA09/S232.

The way in which this works in practice is illustrated by the following example.