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HMRC internal manual

Capital Gains Manual

Restrictions: pre-entry loss: time-apportionment

TCGA92/SCH7A/PARA2 (6A) & (6B)

This defect was corrected by FA94, which inserted new subparagraphs (6A) and (6B) into para 2 Schedule 7A. For the purposes of the time-appointment formula the expenditure is treated as it would have been if the disposal of the asset had been by the company which brought the asset into the group.

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.