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HMRC internal manual

Venture Capital Schemes Manual

Share Loss Relief: individual and corporate claimants: individual claimants: deemed disposals where an asset is lost or destroyed

TCGA92/S24(1) provides that loss, destruction, dissipation or extinction of an asset is a disposal of the asset for the purposes of the Act, so a chargeable gain or allowable loss can arise at that time. For guidance on this subject, see CG13118+.

Section 131(3)(c) ITA 2007 ensures that a deemed disposal under TCGA92/S24(1) is a disposal for Share Loss Relief purposes, so an allowable loss accruing under TCGA92/S24(1)may be the subject of a claim to Share Loss Relief. This is so for claims made by individuals only in respect of loss or destruction etc occurring after 5 April 2000 (for companies the corresponding date is 31 March 2000): there was no provision corresponding to section 131(3)(c) for earlier deemed disposals of this sort, though a concessionary practice ensured a similar result was possible.