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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: special cases

TCGA92/SCH7A/PARA9 (2) (d) & (e)

It is easiest to understand the situations covered by paragraph 9(2)(d) and (e) Schedule 7A in the context of the types of manipulation which would otherwise be possible involving separate capital gains groups under common control.

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.