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HMRC internal manual

Capital Gains Manual

Restrictions: capital losses: time-apportionment: pooled assets


The rules in paragraph 3 Schedule 7A determine the extent to which pre-entry losses on pooled assets can be deducted from gains. They do not displace the general scheme for computing chargeable gains and allowable losses on disposals of pooled assets. Any gain or loss on the disposal of a pooled asset has to be computed applying the general capital gains rules apart from Schedule 7A. If there is a loss, the Schedule 7A rules then apply to establish the pre-entry loss, if any, and the permitted set-off against gains, but they do not affect the overall allowable loss on the disposal.

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.