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HMRC internal manual

Capital Gains Manual

Targeted anti-loss buying rule - special rules for pooled securities

TCGA92/S184F contains a special rule applying to

  • relevant companies with a pre-change asset and
  • other companies that have acquired a pre-change asset following a disposal to which TCGA92/S171(1) applied.

It applies to such companies where the pre-change asset consists of a holding of securities to which the share identification rules in TCGA92/S104 - S111 apply (CG50500+).

Any new securities acquired after the qualifying change in ownership do not form part of the pre-change asset. Where securities are acquired after the qualifying change of ownership they form a single, pooled asset, separate from those forming the pre-change pool.