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HMRC internal manual

Capital Gains Manual

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

Losses can continue to be created, or increased, on disposals on or after 30 November 1993 by amounts of indexation which had been incorporated in a transferee’s acquisition cost on no gain/no loss transfers of an asset before 30 November 1993, see CG17700+. FA1994 inserted new paragraphs 2(8A) and (8B) Schedule 7A to enable the time-apportionment formula to deal with these cases.

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.