TTM08310 - Chargeable gains: Roll over relief
New asset is a tonnage tax asset
No roll-over against tonnage tax asset
Under the normal roll-over relief rules, see CG60250, any gain arising on the eventual disposal of the replacement asset will normally be a chargeable gain. However, gains accruing on tonnage tax assets are not subject to tax, see TTM08100.
A claim to roll-over relief may therefore not be made if the ‘new asset’ is a tonnage tax asset.
This prohibition applies not only to claims which are effected by deducting the gain from the cost of the new asset, see CG60350, but also to claims which are effected by holding over the gain, see CG60370.
Only part of the asset is a tonnage tax asset
Where part only of the new asset is a tonnage tax asset, see TTM08020, a roll-over relief claim may only be made in respect of the expenditure on that part of the new asset which is not a tonnage tax asset.
References
FA00/SCH22/PARA67(1) (S152 and 153 TCGA 1992 not to apply) |