TTM08310 - Chargeable gains: Roll over relief
New asset is a tonnage tax asset
No roll-over against tonnage tax asset
Under the normal roll-over relief rules, see , any gain arising on the eventual disposal of the replacement asset will normally be a chargeable gain.聽 However, gains accruing on tonnage tax assets are not subject to tax, see TTM08100.
A claim to roll-over relief may therefore not be made if the 鈥榥ew asset鈥� is a tonnage tax asset.
This prohibition applies not only to claims which are effected by deducting the gain from the cost of the new asset, see , but also to claims which are effected by holding over the gain, see .
Only part of the asset is a tonnage tax asset
Where part only of the new asset is a tonnage tax asset, see TTM08020, a roll-over relief claim may only be made in respect of the expenditure on that part of the new asset which is not a tonnage tax asset.
References
FA00/SCH22/PARA67(1) (S152 and 153 TCGA 1992 not to apply) |