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HMRC internal manual

Capital Gains Manual

Deduction of pre-entry losses: general


The general rule in TCGA92/S8 (1) states the amount to be included in a company’s total profits for an accounting period in respect of chargeable gains. This is

  • the total of the chargeable gains accruing in the period


  • any allowable losses accruing in the period


  • any allowable losses brought forward from previous periods while the company was within the charge to Corporation Tax.

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.