TCGA 1992 is amended as follows.
In subsection (4) of section 13 (members to whom rule for attributing gains to members of non-resident companies does not apply), for "one tenth" substitute ." one quarter "
In subsection (5) of that section (cases where rule for attributing gains to members of non-resident companies does not apply), after the "or" at the end of paragraph (b) insert—
After section 13 insert—
The amendments made by this section have effect in relation to disposals made on or after 6 April 2012.
But, in the case of a disposal made on or after that date but before 6 April 2013, a person to whom a part of a chargeable gain or allowable loss would (but for the amendments made by this section) have accrued on the disposal may make an election in writing for section 13 of TCGA 1992 to apply in relation to the disposal without those amendments.
An election under subsection (6) in respect of a disposal must be made—