ICAEW.com works better with JavaScript enabled.

TAXguide 09/19: Rebasing and adjustment to the CGT foreign capital losses election

This guide focuses on the areas of uncertainty in the Finance (No. 2) Act 2017 statutory provisions for rebasing and the changes to the CGT foreign capital losses election. It is formed of questions and answers from ICAEW and other professional bodies, together with comments from HMRC.

TAXguide 09/19

This guidance can be downloaded in full.


TAXguide 09/19 is one in a series of pieces of guidance on the taxation of foreign domiciliaries and non-UK resident trusts prepared by committee members of ICAEW, STEP CIOT and The Law Society. The guides aim to highlight areas of uncertainty in the statutory provisions introduced by Finance Act (No 2) Act 2017 with effect from 6 April 2017.

Split into three sections the questions and answers provided in TAXguide 09/19 cover:

  • capital gains tax rebasing;
  • interaction between rebasing and cleansing; and 
  • the CGT foreign capital losses election.

It also includes four appendices outlining the relevant legislation and HMRC guidance.

This guide is intended to assist professional advisers in considering the issue. It does not constitute advice and is not a substitute for professional consideration of the issues by such a professional adviser in each client’s specific context. As such, no liability is assumed to any person in respect of this guide.