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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.

The time apportionment rules in this article apply to assets held by a company on 6 April 1965 other than quoted securities, units in a unit trust scheme and land in the UK reflecting development value, for which see C2.610.

The main rule is that the gain on disposal is treated as having accrued evenly over the whole period of ownership, though the beginning of the period of growth cannot be treated as having started earlier than 6 April 1945¹. The chargeable gain is therefore that proportion of the whole gain which the period from 6 April 1965 to the date of disposal bears to the whole period of ownership; treating the whole period of ownership as beginning on 6 April 1945 if later than the actual date of acquisition..

A company may elect to have the amount of a chargeable gain determined by reference to the market