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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.

It is possible that a company may have made an irrevocable election (a 'universal rebasing' election) that gains and losses on disposals after 5 April 1988 of assets which it held on 31 March 1982 should automatically be calculated using the market value of each asset at 31 March 1982¹. Where such an election has been made, the exceptions to rebasing at C2.603 do not apply and there is no need to perform the kink test.

An election also has the effect of substituting market value at 31 March 1982 in the case of:

1. Ìý

   (a)ÌýÌýÌýÌý disposals which, either on the facts of the case or under TCGA 1992, Sch 2 (see C2.611), give rise to neither a gain nor a loss²; and

2. Ìý

   (b)ÌýÌýÌýÌý specified no gain/no loss disposals³

Subject to the exceptions noted below, an election applies