CG46350 - Groups: rebasing: deferred charges

TCGA92/SCH4

»Ê¹ÚÌåÓýapp result of the various provisions which roll over or postpone gains may be that an event on or after 6 April 1988 would trigger a tax charge on a gain accrued before 31 March 1982 in circumstances where the general rule rebasing gains and losses to 31 March 1982 gives no effective restriction. »Ê¹ÚÌåÓýapp rebasing legislation accordingly includes special provisions in TCGA92/SCH4 which in certain circumstances either halve a deferred tax charge or eliminate it completely. In relation to companies, the provisions affected include

  • TCGA92/S116 (acquisition of qualifying corporate bonds on a reorganisation of share capital including a share exchange, see CG53709+)
  • TCGA92/S140 (outward domestication, see CG45660+)
  • TCGA92/S152 (roll-over relief on replacement of business assets, see CG60250+)
  • TCGA92/S154 (depreciating asset acquired as replacement for business asset, see CG60370+)
  • TCGA92/S178 and TCGA92/S179 (degrouping charges, see CG45400+).

»Ê¹ÚÌåÓýapp provisions which halve or eliminate deferred charges only apply if there is a claim. Further instructions are at CG16980+.