Commentary on Sections Structure of Chapters Overview Section 454: Listed securities held since 26th March 2003: relief for losses
1819.This section provides for any loss sustained on the disposal of a listed deeply discounted security to be relieved by set-off and explains when a loss is incurred. It is based on paragraphs 2 and 6 of Schedule 13 to FA 1996.
1820.Subsection (2) provides that a loss is incurred where the amount paid on acquisition exceeds the amount paid on disposal disregarding any incidental costs. Incidental costs may increase the loss but not create a loss. See section 455 for how the loss is computed.
1821.Subsection (3) signposts section 455(2) to (4) which allow costs in computing the profit where the security has been continuously held since 26 March 2003.
1822.The set-off rules for persons who are not trustees (subsection (4)) differ from those for trustees (subsection (5)).
1823.See paragraphs 82 and 83 of Schedule 2 to this Act for further provisions on trustees.