PART 2THE TREATMENT OF PARTICIPANTS IN NON-REPORTING FUNDS
CHAPTER 5OFFSHORE INCOME GAINS AND THE COMPUTATION OF OFFSHORE INCOME GAINS
Earlier disposal to which the no gain/no loss basis applies40
1
This regulation applies if—
a
a participant is chargeable to corporation tax, and
b
the amount of any chargeable gain or allowable loss which would arise on the disposal would fall to be computed in a way which, in whole or in part, would take account of the indexation allowance on an earlier disposal to which section 56(2) of TCGA 1992 M1 (disposals on a no gain/no loss basis) applies.
2
The basic gain on the disposal is computed as if—
a
no indexation allowance had been available on any such earlier disposal, and
b
subject to that, neither a gain nor a loss had arisen to the person making such an earlier disposal.