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HMRC internal manual

Oil Taxation Manual

Capital gains: extension of ring fence: assets used in connection with oil fields - disposals on or after 22 April 2009 - qualification for relief under TGCA92\S153

TCGA92\S198B and S198C

A disposal and acquisition qualifies for TCGA92\S153 relief if

  • TCGA92\S153(1) applies to part of the amount or value of the consideration for the disposal,
  • TCGA92\S153(1)(a) and (b) would apply to the disposal and acquisition if the appropriate claim were made, and
  • the disposal and acquisition would qualify for roll-over relief but for the disapplication of TCGA92\S152(1) by TCGA92\S153(1);

with the following adjustments

  • TCGA92\S153(2) has effect subject to TCGA92\S198F(4) and (5),
  • TCGA92\S198B is to be disregarded,
  • all the circumstances are taken into account, including TCGA92\S198(1).