Consequential claims etc. not to give rise to reduction in liability
64(1)If in any case—
(a)one or more claims, elections, applications or notices are made, given, revoked or varied under paragraph 62 in consequence of an amendment or assessment, and
(b)the total of the reductions in liability to tax resulting from that action would exceed the additional liability to tax resulting from the amendment or assessment,
the excess is not available to reduce any liability to tax.
(2)Where sub-paragraph (1) has the effect of limiting either—
(a)the reduction in a person’s liability to tax for more than one period, or
(b)the reduction in the liability to tax of more than one person,
the limited amount shall be apportioned between the periods or persons concerned.
(3)The apportionment shall be made in such manner as the Inland Revenue may specify by notice in writing to the person or persons concerned, unless notice is given under the following provision.
(4)If the person concerned gives (or the persons concerned jointly give) notice in writing to the Inland Revenue within the period of 30 days beginning with—
(a)the day on which notice under sub-paragraph (3) is given to the person concerned, or
(b)where more than one person is concerned, the latest date on which such notice is given to any of them,
the apportionment shall be made in such manner as may be specified in the notice given by the person or persons concerned.
(5)In this paragraph “tax” includes income tax or capital gains tax.