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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Groups to which loss set-off restrictions apply: unrealised losses: rule

In addition to the groups covered by the main rules for realised and unrealised losses in paragraph 9(2)(a) and (b), the loss set-off restrictions apply to other groups falling within paragraph 9(2)(c)-(e). If the result of paragraph 9(2) is that there are two or more groups (`connected groups’) to which Schedule 7A applies, the further rules in paragraph 9(3)-(5) come into operation, see CG47940+. And there is a further rule concerning common group membership, in paragraph 9(7), see CG47945.

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.