Readers’ forum: Rollover relief

My corporate client released a large capital gain with proceeds in the order of £1m in the year to 31 December 2020. Qualifying expenditure for rollover relief purposes of at least £2m in total will be incurred on several different assets during the 36 months period from the date of disposal.

It is likely that one or more of those replacement assets will themselves be sold within a couple of years of acquisition but at this stage my client does not know in what order they will be sold.

Can he keep his options open by not allocating the original proceeds against any particular asset until he knows which of the new assets will be sold first? Can he achieve this by using the provisional claim rules in conjunction with the four-year time limit for making claims? Ultimately he accepts that once all of the new assets...