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HMRC internal manual

Capital Gains Manual

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

TCGA92/S184B takes effect whether or not the gain arises before, at the same time as or after the change of ownership, and whether or not there is an allowable loss which can be set against the gain at that time. The tax advantage can arise to the company that has changed hands, or to another company, thus preventing the rules being circumvented, for example by the transfer of assets within a group of companies.