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HMRC internal manual

Capital Gains Manual

Targeted rules to prevent the contrived creation of capital losses by companies - company to which tax advantage arises

The legislation also applies where the tax advantage would otherwise ultimately havearisen to another company.

Specifically, in relation to schemes converting income to capital TCGA92/S184G providesthat the income which would have been taken into account but for the arrangements may havearisen either in the relevant company or in any company in the same CG group.

In relation to schemes securing deductions, TCGA92/S184H provides that the tax advantagemay arise either to the relevant company or any other company.