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HMRC internal manual

Capital Gains Manual

Targeted anti-gain buying rule - choice of commercial options

For example, in a case where TCGA92/S184B may be in point, and the arrangements include the purchase of a company with a crystallised gain or an asset pregnant with a gain, it will be necessary to consider whether that transaction would have proceeded at all if the acquiring company or group 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.