Taxation of Chargeable Gains Act 1992 Schedule 4AA paragraph 20

Capital allowances

Paragraph 20 of Schedule 4AA deals with how capital allowances interact with the rebasing rules for non-residents disposing of UK land or related assets that were held on 5 April 2019 (or 5 April 2015, where applicable).

  • When rebasing applies, the asset is treated as having been acquired at market value on the relevant rebasing date, but any capital allowances previously claimed on the original cost still need to be taken into account.
  • The normal rules restricting allowable losses by reference to capital allowances (section 41 TCGA 1992) continue to apply, but operate as though the allowances related to the rebased market value rather than the original cost.
  • Similarly, the rules for wasting assets that qualify for capital allowances (section 47 TCGA 1992) apply on the same adjusted basis.
  • "Allowance" in this context means any capital allowance or renewals allowance that has been claimed in respect of the asset.

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