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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Restrictions: capital losses: amount of pre-entry loss: introduction

FA94 also corrected a defect in the original provisions which allowed groups to side-step the time-apportionment provisions by transferring assets with unrealised losses within the group, at no gain/no loss, prior to the loss disposal. See CG47630+.

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.