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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Restrictions: capital losses: identifying pre-entry losses: life insurance


TCGA92/S212 provides for an annual deemed disposal of certain life insurance company holdings in trusts and offshore funds. In determining whether a loss accruing to a company on a disposal under Section 212 is a loss which accrued before the company became a member of the relevant group, the spreading provisions in TCGA92/S213 are disregarded.

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.