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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Targeted anti-gain buying rule - commencement

The 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 in CG47334, TCGA92/S184B to F take 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.