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HMRC internal manual

Capital Gains Manual

Restrictions: capital losses: groups to which restrictions apply

A company may be affected by the loss set-off restrictions even if it is no longer a member of any group. This may happen where a pre-entry loss is brought into a group by a company which subsequently leaves the group without becoming a member of any other group. In this situation the loss set-off restrictions continue to apply.

Note: Additional rules relating to loss buying were enacted in FA 2006. See CG47020+ for guidance on the rules which apply in priority to TCGA92/SCH7A for accounting periods ending on or after 5 December 2005.

FA11/S46 and FA11/SCH11 greatly simplified the rules in TCGA92/SCH7A for the deduction of losses on or after 19 July 2011. See CG47400+ for guidance on loss streaming from that date.