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CG16980 gives guidance on the rules in TCGA92/S36 and TCGA92/Sch4 which apply in cases where

• the gain on an asset which was owned on 31 March 1982 and disposed of before 6 April 1988 has been deferred or held over, for example, under the provisions for hold-over relief or roll-over relief, and
• the gain was recovered on a disposal on or after 6 April 1988.

The rules operate to reduce the deferred gain by one half.

The relief, referred to as ‘halving relief�, is extended to apply where the deferred gain relates to an asset that was acquired as a result of a statutory no gain/ no loss transfer from a person who held the asset on 31 March 1982, see CG17002.

SP1/89 part of which is reproduced below enables partners to benefit from halving relief by treating a transfer of an interest in a partnership asset that results in neither a gain nor a loss, see CG27500 and the example at CG27540, as a statutory no gain/no loss transfer for the purposes of TCGA92/Sch4:

A disposal of a share of partnership assets to which paragraph 4 of the statement of practice D12 applies so that neither a chargeable gain nor an allowable loss accrues (before indexation, for disposals before 6 April 1988) may be treated for the purposes of TCGA92/S36 and TCGA92/Sch 4 as if it were a no gain/no loss disposal within TCGA92/Sch 3 para 1.

Under the simplification of CGT rules in FA2008 halving relief is no longer available for disposals on or after 6 April 2008 by non-corporate partners whose gains are chargeable to Capital Gains Tax, see CG16980.