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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Schedule 7AA TCGA 1992: restrictions on capital losses: reorganisation


If a holding of shares owned by a company at the time it entered a group is subject to a reorganisation to which TCGA92/S127 applies, then for the purposes of paragraph 5 Schedule 7AA you disregard that part of Section 127 which determines the time at which anything comprised in `the new holding’ (as defined in TCGA92/S126(1)(b)) is deemed to have been acquired.

Note: New rules relating to gain buying were enacted in FA 2006. See CG47320+ for guidance on the rules which apply for accounting periods ending on or after 5 December 2005.