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HMRC internal manual

Capital Gains Manual

Targeted anti-gain buying rule - general

TCGA92/S184A to F will apply whenever there is a change of ownership of a company (“the relevant company”) that occurs directly or indirectly in consequence of, or in connection with arrangements. Where a main purpose of the arrangements is to secure a tax advantage involving the deduction of a capital loss from any chargeable gains, then that loss may not be deducted from the gains.