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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
Updated
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Groups: restriction of indexation allowance: outline

TCGA92/S182, TCGA92/S183 & TCGA92/S184The provisions in TCGA92/S182 - TCGA92/S184 were introduced to counter arrangements whereby group or associated companies used the indexation provisions to create capital losses on what were essentially intra-group financing arrangements. These rules apply to disposals on or after 15 March 1988 and before 30 November 1993. For disposals on or after 30 November 1993, the provisions of FA94 introduce general restrictions on the extent to which indexation allowance can create or increase a loss, see CG17700+.