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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Restrictions: identifying pre-entry losses: companies rejoining same group

TCGA92/SCH7A/PARA1 (5) (a) & (b)

A company which becomes a member of a group may leave it, and later rejoin the same group. For the purposes of the loss set-off restrictions, where a company joins the relevant group more than once, an asset is a pre-entry asset if the company brings the asset into the group on any of those occasions. And references to the time when a company became a member of the relevant group, in relation to assets held on more than one of those occasions, are references to the latest such occasion.

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.