CG40910 - Computation of gain in non-sterling currency - example

Example of disposal within CTA10\S9C
Example of disposal under CTA10/S9C following intra-group transfer within TCGA92/S171

Example of disposal within CTA10\S9C

On 1 September 2008 Finance One Ltd, a UK company with an US$ functional currency, acquired $200 of shares at a time when their Sterling value was 拢118.

On 1 September 2014 Finance 2 Ltd sold the shares to a third party for 拢350 sterling.

The computation is as follows:-

- Amount
Third party sale 1 September 2014 -
Proceeds of sale 拢350 -
converted into US$ at the spot rate on 1/9/14 (拢350 at 1.6) $560
Less base cost -$200
Indexation 9/08 to 9/14 -$46
Net gain on disposal calculated in US$ $314
Gain converted into sterling at spot rate on date of disposal 拢196

Example of disposal under CTA10/S9C following intra-group transfer within TCGA92/S171

On 1 September 2008 Finance One Ltd, a UK company with an US$ functional currency, acquired $200 of shares at a time when their Sterling value was 拢118.

On 1 September 2012 the shares were transferred to Finance Two Ltd, a fellow group company also with US$ functional currency, in a nil gain/loss transfer under TGCA92/S171 At that time the Sterling value of the shares was 拢125.

On 1 September 2014 Finance Two Ltd sold the shares to a third party for US$400.

The computations are as follows:-

Nil gain/loss transfer September 2012

- Amount
Cost converted to Sterling at date of acquisition 拢118
Add indexation 9/08 to 9/12 拢22
Total 拢140

Transfer deemed to take place for proceeds of 拢140, which will form the base cost of the asset for Finance Two Ltd. As this transfer takes place before CTA10/S9C comes into effect, the deemed proceeds are identified in sterling.

Third party sale September 2014

- Amount Amount
Proceeds in US$ - $400
Less Base cost 拢140 -
Converted to US$ at deemed date of acquisition 9/12(拢140 at 1.6) - -$224
Less indexation* 9/12 to 9/14 - -$24
Net gain on disposal calculated in US$ - $156
Finally, the gain converted into sterling at the spot rate at date of - -
Disposal 1 September 2014 - 拢97

* Indexation calculated as normal on the $US amount.