Commentary

D7.433 Allocating chargeable gains

Corporate tax
Corporate tax | Commentary

D7.433 Allocating chargeable gains

Corporate tax | Commentary

D7.433 Allocating chargeable gains

The allocation of chargeable gains to BLAGAB depends on whether, and to what extent, the asset disposed of is 'matched' to a BLAGAB liability immediately before its disposal.

If the whole of the asset was matched to a BLAGAB liability immediately before disposal, then the whole of the gain is referable to BLAGAB1.

If only part of the asset was matched to a BLAGAB liability immediately before disposal, including a deemed disposal caused by the operation of the asset transfer rules (see D7.453 and D7.455)2, then an appropriate proportion (being that proportion of the gain equalling the proportion of the asset recognised in the

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