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HMRC internal manual

Capital Gains Manual

Targeted anti-loss buying rule - definition of change of ownership

“Change of ownership” means that a company either becomes a member of a group of companies, or ceases to be a member of a group of companies, or becomes subject to different control. The wide definition of “change of ownership” is designed to prevent artificial arrangements under which, for example, a company’s membership of a group changes for tax purposes when the economic reality is that it does not. However HMRC would not normally consider the incorporation of a company or the acquisition from a company formation agent of a newly formed company as amounting to a change of control.