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HMRC internal manual

Capital Gains Manual

Groups to which loss set-off restrictions apply: introduction

You should bear in mind that company takeovers or reconstructions may not be treated as involving any change of group. There are special rules in these cases, see CG47569, and cases where a company joins the same group on more than one occasion, see CG47568. Also the provisions of paragraph 12 Schedule 7A may apply where a company changes group on a no gain/no loss disposal, see CG47572.

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.