Taxation of Chargeable Gains Act 1992 Schedule 4ZZA paragraph 6A

Special rule for certain disposals to which both Schedule 4ZZA and Schedule 4ZZB relate

Paragraph 6A of Schedule 4ZZA provides a special rule for calculating gains on disposals that fall within the scope of both the investors' relief rules (Schedule 4ZZA) and the business asset disposal relief rules (Schedule 4ZZB).

• Where a disposal qualifies under both the investors' relief provisions and the business asset disposal relief provisions, a special ordering rule applies to determine how the gain is taxed.
• The purpose of this rule is to prevent double relief by ensuring that the same gain cannot benefit from both the reduced capital gains tax rate available under investors' relief and the reduced rate available under business asset disposal relief.
• The rule establishes which relief takes priority when both could potentially apply to the same disposal, ensuring a clear and consistent tax treatment.
• This provision was introduced by the Finance Act 2019 to address the interaction between these two reliefs and provide certainty for taxpayers disposing of qualifying shares.

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