OT68030 - Transferable tax history - Onward sales - Effect on the original purchaser
Where there is an onward sale, and a TTH election is made by the original purchaser and the new purchaser, and as a result, some or all of any unused transferred profits amount of the original purchaser relating to the original TTH election is transferred to the new purchaser, that unused transferred profits amount so transferred ceases to be treated as a transferred profit amount of the original purchaser for the purposes of the original TTH election.
As a result, that amount that is transferred on in the onward sale can never be activated by the original purchaser, no loss of the original purchaser can ever be set against it, and no repayment can be made to the original purchaser of any tax paid on those profits.