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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Restrictions on setting off capital losses: privatisations


There are special rules in paragraph 11 Schedule 7A dealing with the interaction between Schedule 7A and the tax provisions in privatisation legislation, see CG45750. In broad terms, the loss set-off restrictions do not apply in relation to the transfer of capital losses or loss assets from one person to another on a privatisation or other public sector restructuring.

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.