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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. Re-acquisition cost of assets

CG39195 | Re-acquisition cost of assets

From HM Revenue & Customs · Capital Gains Manual

If the deemed disposal and reacquisition is of only a proportion of the remaining chargeable assets the base cost of those assets will be made-up of two elements:

  • an element representing the deemed disposal and reacquisition

  • an element representing the remaining original cost.

Suppose an asset cost £6,000 and the trustees are treated as disposing of 2/3 rds of the asset. If the asset has a market value of £13, 500 the deemed disposal and reacquisition gives a gain of £5,000 (£9,000 - £4,000). The remaining part of the original cost is £2,000 (£6,000 - £4,000).

The base cost of the reacquired asset is £11,000 made up of two elements:

  • £9,000 - the market value of the part disposed of

  • £2,000 - the remaining part of the original cost.

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