CG46362 - Groups: rebasing: group elections out of the kink test: time limits
Taxpayers can make an election at any time before 6 April 1990. Thereafter they can make an election at any time during the period which begins with the first relevant disposal' and ends two years after the end of the accounting period in which that disposal is made. For this purpose
the first relevant disposal’ is the first disposal to which Section 35 applies which is made by the person making the election. The Board have statutory discretion to extend the time limit in particular cases.