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C2.610 Assets held by a company on 6 April 1965—overview

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

When tax on capital gains was introduced in 1965, the intention was to exclude from charge gains accrued but unrealised on 6 April 1965. The legislation therefore includes special provisions in TCGA 1992, Sch 2 which seek, broadly, to achieve that intention¹.

For most disposals by companies the provisions are now displaced by the rebasing rules for assets held on 31 March 1982 (see C2.602), but they may still be relevant for certain disposals. See further below for how the provisions interact with the rebasing provisions.

The provisions do not apply to disposals which are covered by a universal rebasing election (see C2.604); for such disposals, the chargeable gain or allowable loss is always calculated using the 31 March 1982 market value as the base cost.

The provisions also do not apply to disposals by individuals or trustees