The commentary in this article applies for corporation tax purposes. See C2.601A for capital gains tax purposes.
Where there is a part disposal of an asset, TCGA 1992, s 42 provides for the apportionment of the allowable expenditure (see C2.402). That apportionment then determines the allowable expenditure when the remainder of the asset is disposed of. Where the asset was held by the company on 31 March 1982, the calculations must take account of the rebasing rules.
For HMRC internal guidance as to rebasing following a part disposal, see CG16940–CG16960.
The effect of rebasing depends on whether the part disposal took place before 1 April 1982, after 5 April 1988 (when rebasing was introduced) or between those dates. The main possibilities are broadly summarised in the table below. More detailed commentary follows the table.
Date of part disposal | Rebasing rules |
After 5 April 1988 | In calculating the allowable expenditure on the part disposal, normal rebasing rules apply (including, where relevant, the kink test). |
After 31 March 1982 and before 6 April |
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