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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Transactions between connected persons

TCGA92/S18

Where the person who acquires an asset is connected with the person making the disposal, see CG14580, they are to be treated as parties to a transaction otherwise than by way of bargain at arm’s length. This brings the market value rule in TCGA92/S17 into operation. In addition TCGA92/S18 provides that any loss on the transaction becomes a ‘clogged loss’.