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The commentary in this article applies for corporation tax purposes. There are now no equivalent rules for capital gains tax purposes.

Rebasing, ie the substitution of the market value at 31 March 1982 in the case of an asset held at that date, does not apply in certain circumstances, namely:

1. Ìý

   (a)ÌýÌýÌýÌý where the substitution would increase the gain, or substitute a gain for a loss

2. Ìý

   (b)ÌýÌýÌýÌý where the substitution would increase the loss, or substitute a loss for a gain

3. Ìý

   (c)ÌýÌýÌýÌý where, either on the facts of the case or by virtue of TCGA 1992, Sch 2 (assets held at 6 April 1965, see C2.610–C2.613), neither a gain nor a loss would otherwise arise

4. Ìý

   (d)ÌýÌýÌýÌý where the disposal is a specified no gain/no loss disposal¹

In other words, rebasing can only reduce a chargeable gain or an allowable loss; it may not create or increase a chargeable gain, nor create or increase an allowable loss. These exceptions