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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Targeted rules to prevent income to capital converter schemes by companies - definition of tax advantage

For the purposes of TCGA92/S184G, the definition of tax advantage in TCGA92/S184Dapplies (see CG44103), but the tax advantage must also involve the deduction of lossesfrom the relevant gain.