Commentary

C2.613 Part disposals

Capital gains tax
Capital gains tax | Commentary

C2.613 Part disposals

Capital gains tax | Commentary

C2.613 Part disposals

The provisions below only apply to companies (see C2.610).

Although no chargeable gains or allowable losses arise in respect of disposals before 7 April 1965, the capital gains tax provisions apply to such disposals in so far as material to the computation of gains on disposals occurring after that date1. In the case of part disposals (see Division C2.4), however, the normal rule for determining allowable expenditure is modified in the case of assets held at 6 April 1965 if there was a part disposal of the asset before that date. Instead of computing the notional allowable expenditure on the earlier part disposal2, the asset remaining is deemed to have been disposed of and immediately reacquired at its market value on the date of the earlier part disposal3. This means that the period of ownership for the purposes of any time apportionment calculation begins with the date of the part disposal, not with the date of the original acquisition of the asset.

The disponor may elect, in relation to a subsequent disposal, that the asset be treated as having been disposed of and

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial