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HMRC internal manual

Capital Gains Manual

Capital loss buying: approach prior to FA 1993: general

There is no form of group relief for the capital losses of companies. However, as explained at CG45300 groups can take advantage of the no gain/no loss rule for intra-group asset transfers to achieve much the same result. You should not challenge the transfer of assets from one group member to another at no gain/no loss under TCGA92/S171, where this brings gains and losses together in a single company, provided that both the gain and the loss are wholly attributable to changes in value while the assets were in the ownership of the 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.