Taxation of Chargeable Gains Act 1992 section 164D

Relief carried forward into replacement shares

Section 164D provided a mechanism by which rollover relief on gains from disposals of shares could be carried forward and attached to replacement shares, reducing their base cost for future capital gains purposes. This section was repealed for acquisitions made on or after 6 April 1998.

• Section 164D allowed capital gains tax relief to be "rolled over" into the cost of replacement shares, effectively deferring the tax charge until the replacement shares were themselves disposed of.
• The relief worked by reducing the acquisition cost (base cost) of the new replacement shares by the amount of the gain that was rolled over, so that when those shares were eventually sold, the deferred gain would be brought back into charge.
• This provision formed part of a broader rollover relief regime contained in Chapter 1A (sections 164A to 164N) of the Taxation of Chargeable Gains Act 1992, which collectively dealt with relief on the reinvestment of gains into qualifying shares.
• The entire Chapter 1A, including section 164D, was repealed by the Finance Act 1998 for share acquisitions made on or after 6 April 1998, meaning this relief is no longer available for transactions from that date onwards.

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