Readers’ forum: Disclosing gains if taxpayer is not within self assessment

My question concerns disclosure of capital gains (and I am not concerned here with residential property gains). I know that if a client is already within self assessment (SA) there is no requirement to include any information on the return if the gain is covered by the annual exempt amount unless the proceeds are over £50 000. But what is the position of somebody who is not within SA and who has not been issued with a return?

TMA 1970 s 7 says that there is a requirement to notify gains unless a person has no ‘chargeable gains’. But I read TGCA 1992 s 1K as saying that the annual exempt amount is deducted from chargeable gains – which implies that any disposal at a profit of a chargeable asset gives rise to a chargeable gain and therefore there is a disclosure obligation even if no CGT is payable. That...