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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Gains from which pre-entry losses are deductible: losses pre-entry

If a company joining a group has an allowable loss which accrued (that is, was realised) pre-entry, the loss can be deducted from the categories of gains described in CG47772-CG47776.

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.