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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.

Where the time apportionment rules (see C2.611) apply to the disposal of an asset, the company may elect to have the amount of the chargeable gain determined instead by reference to the market value of the asset in question at 6 April 1965¹. The asset is then treated as acquired by the owner at its market value² on 6 April 1965³. An election must be made by notice in writing:

1. Ìý

   (a)ÌýÌýÌýÌý within two years after the end of the accounting period in which the disposal is made; or

2. Ìý

   (b)ÌýÌýÌýÌý within such later time as HMRC may by notice allow⁴

HMRC takes the view that where the charge is a degrouping charge resulting from a company leaving a group (see D2.333), the election must be made within two years after the end of the