Taxation of Chargeable Gains Act 1992 section 164MA

Exclusion of double relief

Section 164MA prevented taxpayers from claiming rollover relief on the reinvestment of gains into qualifying investments more than once in respect of the same chargeable gain. This section was part of a broader set of provisions (Chapter 1A) that were repealed for acquisitions made on or after 6 April 1998.

• Section 164MA was an anti-avoidance measure designed to prevent the same chargeable gain from attracting rollover relief more than once through reinvestment into qualifying investments.
• The section formed part of Chapter 1A of the Taxation of Chargeable Gains Act 1992 (sections 164A to 164N), which provided relief when gains were reinvested in certain qualifying assets.
• The entire Chapter 1A, including section 164MA, was repealed by the Finance Act 1998 and no longer applies to acquisitions made on or after 6 April 1998.
• Any claims for relief under these provisions could only relate to acquisitions made before 6 April 1998, and the double relief exclusion ensured that the same gain could not be sheltered more than once under this regime.

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