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Whilst I have never seen it stated as such authoritatively, I believe that the interaction of taper relief and prior years' losses is such that no taper relief at all can be given, in effect, against current year gains, until all capital gains tax losses brought forward have been fully utilised.
Whilst I have never seen it stated as such authoritatively I believe that the interaction of taper relief and prior years' losses is such that no taper relief at all can be given in effect against current year gains until all capital gains tax losses brought forward have been fully utilised.
David Kitson in Tottel's Taper Relief (fifth (2005) edition chapter 12.21) comments that 'there is no … provision to prevent the waste of losses — current or earlier years — arising from taper relief'. In an example which he has just given he says 'there is wasted annual exempt amount arising because of taper relief. There is no mechanism to use loss relief to leave [the annual exempt amount] after taper to be covered by the annual exempt amount'. I believe that this supports my view that in practice it is...
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