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HMRC internal manual

Capital Gains Manual

Gains on assets held on entry into a group: pooled or merged assets

The same kind of issue arises where an asset not held before the relevant time (see CG47567) is treated as the same as an asset which was held before the relevant time. Examples are freeholds merged with leasehold interests, paragraph 1(8) Schedule 7A, and post-reorganisation new holdings treated as the same asset as the original shares, TCGA92/S127.

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.