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HMRC internal manual

Capital Gains Manual

Groups: loss restriction by reference to capital allowances

The capital gains rules eliminate double relief by restricting the expenditure taken into account in a loss computation. Expenditure is excluded by TCGA92/S41 (2) to the extent that any capital allowance or renewals allowance has been or may be made in respect of it. There are further rules extending the loss restriction where there is effective continuity of treatment between different persons for capital allowances or capital gains purposes.