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Official guidance
Capital Gains Manual

CG39100P · Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Anti-avoidance legislation – flip-flop schemes: History TCGA92/Sch4B and 4C

  • CG39100 · History TCGA92/Sch4B and 4C
  • CG39105 · TCGA92/Sch4B - transfers of value linked to trustee borrowing - outline
  • CG39110 · TCGA92/Sch4B - applies only to non-resident settlements
  • CG39115 · TCGA92/Sch4B - transfer of value
  • CG39120 · Transfer creates a new asset
  • CG39125 · TCGA92/Sch4B - "the material time"
  • CG39130 · TCGA92/Sch4B - What is trustee borrowing?
  • CG39135 · TCGA92/Sch4B - 'proceeds' of trustee borrowing
  • CG39140 · TCGA92/Sch4B - transfer of value linked with trustee borrowing
  • CG39145 · TCGA92/Sch4B - Application of proceeds of borrowing for normal trust purposes
  • CG39150 · TCGA92/Sch4B - payment in respect of ordinary trust assets
  • CG39155 · Meaning of 'ordinary trust assets'
  • CG39160 · Alternative test for TCGA92/Sch4B/para6(2)(b) to apply
  • CG39165 · Borrowing to acquire freehold interest let on a commercial basis
  • CG39170 · TCGA92/Sch4B - discharge of a loan obligation
  • CG39175 · TCGA92/Sch4B - payment of ordinary trust expenses
  • CG39180 · TCGA92/Sch4B - deemed disposal of remaining chargeable assets
  • CG39185 · Deemed disposal - defined terms
  • CG39190 · Disposal of the whole or part of each asset?
  • CG39195 · Re-acquisition cost of assets
  • CG39200 · TCGA92/Sch4B - value of asset attributable to trustee borrowing - outline
  • CG39205 · Value of asset attributable to trustee borrowing - detail
  • CG39210 · TCGA92/Sch4B - tax charge
  1. Capital Gains Manual: Trusts and Capital Gains Tax: Non-resident trusts: Anti-avoidance legislation – flip-flop schemes: History TCGA92/Sch4B and 4C: contents
  2. Deemed disposal - defined terms

CG39185 | Deemed disposal - defined terms

From HM Revenue & Customs · Capital Gains Manual

TCGA92/Sch4B/para11

The deemed disposal fractions in TCGA92/Sch4B/para11 use a number of defined terms.

VT = amount of value transferred

VT is defined in TCGA92/Sch4B/para2 for each of the three types of transfer of value, CG39115.

  • A loan is the market value of the loan. The market value of sterling is its amount.

  • A transfer is the market value of the asset reduced by any consideration received unless any part of the value of the asset is attributable to trustee borrowing, CG39205.

  • A security is the value of the security reduced by any consideration received.

EV = effective value of remaining chargeable assets

EV is the aggregate market value of those assets immediately after the transfer as reduced by any amount of that value which is attributable to trustee borrowing, CG39205.

TB = outstanding trustee borrowing

TB is defined in TCGA92/Sch4B/para5, CG39140. Money borrowed before 21 March 2001 may still be outstanding trust borrowing.

Remaining chargeable assets

‘The remaining chargeable assets’ are defined in TCGA92/Sch4B/para10(1)(b). They are the chargeable assets remaining in the settlement immediately after the material time; in other words immediately after the transfer of value. An asset is a chargeable asset if a gain on the disposal of the asset would be a chargeable gain.

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