Restrictions: capital losses: no gain/no loss disposals
There are rules protecting the position of companies changing groups on no gain/no loss disposals of shares or securities, for example, under the company reconstruction provisions in TCGA92/S139. See CG47572.
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.