Skip to content
Solved
SearchBrowse
Sign in

Contents

Official guidance
Capital Gains Manual

CG38845P · Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Charge on beneficiary of non-resident settlement – TCGA92/S87: Paragraph 126 elections - 'rebasing'

  • CG38845 · Paragraph 126 elections: time limit for making election
  • CG38850 · Paragraph 126 elections: how to make the election
  • CG38855 · Paragraph 126 elections: when does the election apply?
  • CG38860 · Paragraph 126 elections: what is the effect of the election?
  • CG38865 · Basic operation of FA08/Sch7/para126 - example
  • CG38870 · FA08/Sch7/para126(8) - relevant proportion is 0 - example
  • CG38875 · FA08/Sch7/para126 and section 13 TCGA
  • CG38880 · FA08/Sch7/para126 and section 13* gains - example
  • CG38885 · FA08/Sch7/para126 and section 13 losses - example
  • CG38890 · FA08/Sch7/para126 and transfers between settlements
  • CG38895 · Effect of FA08/Sch7/para126 on transfers between settlements - example
  • CG38900 · FA08/Sch7/para126 and transfers between settlements owning non-UK resident companies
  • CG38905 · FA08/Sch7/para126 elections and transfers of non-resident close companies - example
  1. Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Charge on beneficiary of non-resident settlement – TCGA92/S87: Paragraph 126 elections - 'rebasing': contents
  2. FA08/Sch7/para126 and section 13 losses - example

CG38885 | FA08/Sch7/para126 and section 13 losses - example

From HM Revenue & Customs · Capital Gains Manual

The facts are the same as in CG38880 except that the 6 April 2008 value of the assets sold by Y Ltd is £1.4m. This produces a loss of £200,000 by reference to the 6 April 2008 value (£1.2m - £1.4m). The appropriate proportion of this loss is £150,000 but it cannot be attributed to the trustees.

The relevant proportion of beneficiary B’s £100,000 section 87 gain is calculated by reference to the rebased value of the assets sold by the trustees and the £80,000 gain on the disposal of Y Ltd’s assets which are not relevant assets.

£100,000x(£40,000 + £80,000)=£23,076
--£520,000-
PreviousNext
PrivacyTerms