CG38870 | FA08/Sch7/para126(8) - relevant proportion is 0 - example

From HM Revenue & Customs · Capital Gains Manual

The facts are the same as that in example 22 year 2013-14 except for the 6 April 2008 value of the assets sold. This is £120,000.

The calculation is now:

-Held 06/04/2008Acquired after 06/04/2008Total
Gain£5,000£15,000£20,000
Disposal proceeds£70,000--
06/04/2008 value£120,000--
Loss£50,000--

The section 2(2) amount calculated using 6 April 2008 values is £15,000 - £50,000. This is restricted to 0 as a section 2(2) amount cannot be negative. Beneficiary Z is not liable to Capital Gains Tax on any of the £10,000 2013-14 gain ie £10,000 × 0 = 0. Z remains liable to Capital Gains Tax on the section 87 gain matched to the 2012-13 section 2(2) amount. As in example 22 this is £694.

Z’s capital payments for 2009-10 are still reduced to nil.