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HMRC internal manual

Capital Gains Manual

Targeted anti-loss buying rule - time of loss accrual and company to which tax advantage arises

The additional loss buying rules in TCGA92/S184A to F take effect whether or not the loss arises before, at the same time as, or after, the change of ownership, and whether or not there is a chargeable gain from which it may be deducted at that time. The legislation also applies whether or not the tax advantage arises to the company that has changed ownership or to another connected company. This prevents the rules from being circumvented, for example, by the transfer of assets within a group.