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HMRC internal manual

Capital Gains Manual

Deduction of pre-entry losses: order of set-off: APs 16/3/93p

For accounting periods ending on or after 16 March 1993, the deduction of any particular pre-entry loss from any particular gain is as specified in any election made for the purpose by the company to which the loss accrued. The time limit for an election is two years from the end of the accounting period in which the gain accrued.

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.