CG38725 | Matching in a later year - more than one year - example - the rules for 2008-09 to 2017-18

From HM Revenue & Customs · Capital Gains Manual

2013-14

DescriptionAmount
Trustees’ section 2(2) amount£60,000
Capital payments beneficiary A£20,000

2012-13

DescriptionAmount
Trustees’ section 2(2) amount£nil
Capital payments beneficiary D£30,000

2011-12

DescriptionAmount
Trustees’ section 2(2) amount£nil
Capital payments beneficiary E£25,000

This example illustrates the principle that capital payments are matched taking the latest year first.

Section 87 gains

The £60,000 section 2(2) amount in 2013-14 is matched first against A’s 2013-14 capital payment of £20,000, then against D’s 2012-13 capital payment of £30,000 and finally against £10,000 of E’s 2011-12 capital payment of £25,000 leaving E with unmatched capital payments of £15,000 in 2011-14.

The gains of £20,000, £30,000 and £10,000 all accrue in 2013-14. In practice it is unusual for capital payments to be made before the gains accrue to the trustees.