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HMRC internal manual

Capital Gains Manual

Administration: losses: targeted rules to prevent the contrived creation of capital losses - tax advantage - choice of commercial options

It will be relevant to draw a comparison in order to consider whether, in the absenceof the tax considerations:

  • the transaction giving rise to the advantage would have taken place at all;
  • if so, whether the tax advantage would have been of the same amount; and

whether the transaction would have been made under the same terms and conditions.