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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: connected groups

If a loss on the disposal of an asset is a loss realised pre-entry in relation to any of the connected groups, the realised loss becomes the pre-entry loss for the purposes of paragraph 6 Schedule 7A, see CG47880+.

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.