HMRC have updated their guidance in the Capital Gains Manual on the effect of TCGA 1992, s. 49. The section provides that:
- no account is initially taken of the contingent liability in computing a capital gain; but
- the gain or loss can be recomputed when the liability is enforced.
HMRC have clarified their guidance to show that the time limit in TMA 1970, s. 43 (general tax rule re time limit for making claims) applies from the date when all of the conditions for making a claim are met.
https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg14805
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Written for accountants and other tax advisers at an intermediate level, Capital Gains Tax is built firmly on a foundation of statutory rules and case law principles. It is illustrated throughout with practical examples, and most chapters include a summary of pitfalls and planning points.
