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HMRC internal manual

Capital Gains Manual

Foreign currency: assessment of deferred gains

TCGA92/S279 (2)

In a case where a claim under Section 279 is accepted the deferred gain is assessed in the year, or years, in which the conditions in [## TCGA92/S279 (2) {#IDAVNUQF}

In a case where a claim under Section 279 is accepted the deferred gain is assessed in the year, or years, in which the conditions in](https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg78401) cease to be satisfied (in respect of the whole gain or any part of it not assessed).

 

Amount assessable

The amount which becomes assessable is computed by converting the currency proceeds of the disposal of the asset at the exchange rate prevailing at the date of disposal of the asset. This amount will also be the `cost’ of the currency so acquired.

 

Treatment of currency

Where the currency derived from the disposal of the asset is disposed of (for example by being converted to sterling or another currency, or by being spent), there will be a chargeable gain or allowable loss by reference to the cost as above, and the value of the currency disposed of (converted at the exchange rate prevailing at the date of its disposal).

 

Claims

Claims under TCGA92/S279, should be submitted to Capital Gains Technical see CG99998. Cases in which it is alleged that remittances have been delayed may be referred by Debt Management. If in such cases there are insufficient grounds for discharging the tax, Debt Management  should be so informed and given an explanation of the circumstances.