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HMRC internal manual

Capital Gains Manual

Restrictions: pre-entry loss: time-apportionment: allowable expenditure


Relevant allowable expenditure is defined in paragraph 2(9) Schedule 7A as amounts within TCGA92/S38 (1)(a) or (1)(b). For time-apportionment purposes these amounts are, however, subject to adjustments:

  • in relation to disposals before 30 November 1993, see CG47622;
  • in relation to disposals on or after 30 November 1993, see CG47623+.

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.