s574 relief over 2 years

s574 relief over 2 years

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I have a client who has shares in an unquoted trading company that are now worthless. The cost of the shares are such that claiming loss relief in 1 year only would mean that not all of the losses would be relieved at 40%. If however I could split the loss (by way of two part disposals under s24TCGA 1992?) would I be able to make partial claims and maximise the relief over 2 tax years?
Stephen Smith

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By stevie63
02nd Apr 2009 08:48

Thanks Ken. Worth asking!

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By kenmoody
01st Apr 2009 11:26

No
You can't have use s24 to create a part disposal. If you claim under s24 it is a disposal of the entire asset either at the date of claim or on a date specified in the last two years - provided that the asset was then of negligible value. That's the only flexibility other than that a loss claim under s574 is for the current or the preceding year, so that may achieve what you want but whichever way you go you would have to cover the whole of the income for that year before any balance would be available against the other year. You can't say you want £X against CY and £Y against PY.

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