Taxation of Chargeable Gains Act 1992 section 112

Parallel pooling regulations: corporation tax

Section 112 deals with the transitional provisions for the parallel pooling of shares, preserving the effect of the Capital Gains Tax (Parallel Pooling) Regulations 1986 and setting out the rules for revoking parallel pooling elections.

• The Capital Gains Tax (Parallel Pooling) Regulations 1986 continue to have effect despite the repeal of Schedule 19 to the Finance Act 1985 by this Act.
• Any election for parallel pooling under Schedule 6 to the Finance Act 1983 that was not revoked before 6 April 1992 ceased to have effect for disposals after 5 April 1992, but could be formally revoked with HMRC's agreement.
• Where a company did not revoke its parallel pooling election, the parallel pool holding as at 31 March 1985 had to be disaggregated into a 1982 holding and a section 104 holding, following the rules in the 1986 Regulations.
• All necessary adjustments, including discharge or repayment of tax, must be made as a consequence of any revocation of a parallel pooling election.