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HMRC internal manual

Capital Gains Manual

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

For example, in a case where TCGA92/S184A may be in point (loss buying - see CG47020),and the arrangements include the purchase of a company with accumulated capital losses, itwill be necessary to consider whether that transaction would have proceeded at all if thecompany had not been in possession of capital losses. If it would, then it would also benecessary to consider, for example, whether the benefit of the capital losses had asignificant effect on the terms and conditions of the acquisition.