A chargeable gain under TCGA92/S284A (3) arises only where the relevant circumstancesoccur on or after 9 March 1999, see CG13655. Cases may come to light where thecircumstances occurred before 9 March 1999 and the taxpayer wishes to ignore the previousconcessionary relief. The proper treatment of any such cases will depend on the full factsand circumstances. But in particular it will depend on whether the taxpayer's liabilityfor the chargeable period in which the concessionary relief would normally be recovered isfinal or not.

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