CG73912 - Non-Resident Capital Gains Tax (NRCGT) – Disposals on or after 6 April 2015 to 5 April 2019: Interaction between Non-Resident CGT and ATED-related CGT: Capital allowances for purposes of Sch 4ZZB

Sch 4ZZB/para 25 explains how capital allowances should be taken into account when calculating gains and losses on certain disposals, including relevant high value disposals.

It addresses various cases where it is to be assumed for the purpose of the computation that an asset was acquired by a person on 5 April 2015 or 5 April 2016 for a consideration equal to its market value on that date. The cases are -

• the notional post-April 2015 gain or loss accruing to a person on a non-resident CGT disposal in accordance with Sch 4ZZB/para 5(2),
• the notional post-April 2015 gain or loss accruing to a person on a relevant high value disposal in accordance with Sch 4ZZB/para 13(3),
• the notional post-April 2016 gain or loss accruing to a person on a relevant high value disposal in accordance with Sch 4ZZB/para 15(5),
• the notional pre-April 2016 gain or loss accruing to a person on a disposal in accordance with Sch 4ZZB/para 15(7).

For the purposes of those computations, the provisions of TCGA92/S41 (restriction of losses by reference to capital allowances etc) and S47 (wasting assets qualifying for capital allowances) are to apply in relation to any capital allowance or renewals allowance made in respect of the expenditure incurred by the person in acquiring or providing the asset, as if that allowance were made in respect of the expenditure treated as incurred by the person on 5 April 2015 or 5 April 2016.