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HMRC internal manual

Capital Gains Manual

Groups to which loss set-off restrictions apply: realised losses: rule

TCGA92/SCH7A/PARA9 (2) (a)

The main general rule for realised losses is in paragraph 9(2)(a) Schedule 7A. The loss set-off restrictions apply to a group into which a company brings a realised loss. Except that where there is more than one such group, the loss restrictions only apply to the latest group.

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.