OT62010 - Transferable tax history - Effect of a TTH election on the seller - Profits cease to be treated as the sellers

Where a buyer and seller have made a joint election in respect of a TTH asset, and that election has been accepted by HMRC, the seller will immediately and irreversibly be treated for the purposes of the loss carry back rules as if it had not made those profits included in the election.

The seller is also to be treated as never having paid the tax due on those profits.

As a result, the seller can never get any relief or repayment in respect of those profits, or the tax paid on those profits.