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HMRC internal manual

Capital Gains Manual

Targeted anti-loss buying rule - commencement

The new provisions in TCGA92/S184A to F apply where a tax advantage arises on or after 5 December 2005. This can include situations where a loss arose prior to 5 December, but where the gain that it might otherwise have reduced arises on or after that date.

As explained at CG47034, 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.