What does paragraph 50 of Schedule 5AAA TCGA 1992 do?

Paragraph 50 limits the information reporting requirements under paragraph 14 of Schedule 5AAA. It provides that the obligation to report disposal information to HMRC does not apply to any disposals by participants in UK property rich collective investment vehicles that were made before 6 April 2019.

From what date must disposal information be reported under Schedule 5AAA?

Disposal information must be reported to HMRC for disposals occurring on or after 6 April 2019. Paragraph 50 sets this as the effective start date, meaning any disposals by participants in UK property rich collective investment vehicles before that date are outside the scope of the reporting obligation.

Why does paragraph 50 exclude disposals before 6 April 2019 from reporting?

The exclusion reflects the fact that the Schedule 5AAA rules were introduced by the Finance Act 2019 and came into effect from April 2019. It would be unreasonable to require retrospective reporting of disposals that took place before the regime was in operation, so paragraph 50 ensures no such obligation arises.

Does paragraph 50 affect disposals made after 6 April 2019?

No. Paragraph 50 only excludes disposals made before 6 April 2019 from the reporting requirements. Any disposal by a participant in a UK property rich collective investment vehicle occurring on or after 6 April 2019 remains fully subject to the information reporting obligations under paragraph 14 of Schedule 5AAA.

Taxation of Chargeable Gains Act 1992 Schedule 5AAA paragraph 50

Elections under paragraph 12 and information about disposals by participants

Paragraph 50 limits the information reporting requirements for disposals by participants in UK property rich collective investment vehicles, ensuring they do not apply to disposals before a specified date.

The paragraph concerns the reporting of disposal information under the rules for UK property rich collective investment vehicles.
The information requirements set out in paragraph 14 of Schedule 5AAA do not extend to disposals made before 6 April 2019.
This effectively sets 6 April 2019 as the start date from which disposal information must be reported to HMRC.
Any disposals by participants that took place prior to that date are outside the scope of the reporting obligation.

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