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HMRC internal manual

Capital Gains Manual

Groups to which loss set-off restrictions apply: TCGA92 SCH7A PARA9


In cases which do involve more than one group, the rules which determine the relevant group or groups where the loss set-off restrictions apply are in paragraph 9 Schedule 7A. The starting point for these rules is that a loss accrues to a company on the disposal of an asset. They provide that the loss set-off restrictions only apply to a group if it is a group specified in paragraph 9(2).

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.