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HMRC internal manual

Capital Gains Manual

Targeted anti-loss buying rule - choice of commercial options

For example, in a case where TCGA92/S184A may be in point, and the arrangements include the purchase of a company with accumulated capital losses, it will be necessary to consider whether that transaction would have proceeded at all if the company had not been in possession of capital losses. If it would, then it would also be necessary to consider, for example, whether the benefit of the capital losses had a significant effect on the terms and conditions of the acquisition.