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HMRC internal manual

Capital Gains Manual

CG46370 - Groups: rebasing: elections out of kink test: first disposal

The general rule is that the first disposal to which applies, and which is made by any company in the group, is the first relevant disposal for the group as a whole. This disposal establishes the time limit for the election by the principal company. There are special rules for disposals by outgoing companies and incoming companies.

If an outgoing company made the first disposal in the group to which applies, that disposal is disregarded in determining the group's first relevant disposal. This is the result of .

The reference in to the first relevant disposal includes the first disposal to which applies which is made by an incoming company. This is the result of . In effect an incoming company is treated as though it were a member of the group at the time it made its first disposal to which applies.