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HMRC internal manual

Capital Gains Manual

Capital loss buying: approach prior to FA 1993: general

As soon as the possibility of a loss buying scheme comes to light you should liaise with the Inspectors dealing with the other company or companies involved and make such other enquiries as are necessary to establish the full facts. You may meet the argument that, following the News International case, the Ramsay approach cannot be applied to capital loss buying cases. This is not our view. Further background is given at CG48005 - CG48007.

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.