CG12735 - Part disposals: no gain/no loss disposals

makes it clear that the provisions for the apportionment of cost on a part disposal are to be operated before the various provisions which secure that, in certain circumstances, neither a gain nor a loss is deemed to have arisen on a disposal, see CG14500.

Example

X and Y are spouses, or civil partners, or members of a group of companies. X has an asset which cost 拢40,000 and transfers part of the asset to Y. At the time of the transfer, the market value of the part transferred was 拢30,000. The market value of the part retained was 拢20,000.

The part disposal rules are applied on the basis that the part of the asset transferred to Y was disposed of at market value. The part of the cost apportioned to the disposal is

拢40,000 x (拢30,000 / 拢30,000 + 拢20,000)) = 拢24,000

For the purposes of any later disposal by X the adjusted cost of the remainder of the asset is

拢40,000 - 拢24,000 = 拢16,000.

Y has an acquisition cost of 拢24,000 in respect of the part of the asset transferred to them.