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HMRC internal manual

Capital Gains Manual

Targeted rules to prevent income to capital converter schemes by companies - no double taxation

Where both TCGA92/S184G and existing anti-avoidance rules could potentially apply tothe same transaction, double taxation will not arise (for example through the restrictionof losses used against a capital gain and re-characterisation of all or part of theconsideration as an income profit). This is because TCGA92/S37(1) acts to disregard, incomputing the amount of the consideration for chargeable gains purposes, any amount takeninto account in computing the income of the person making the disposal.