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HMRC internal manual

Capital Gains Manual

Substantial shareholdings exemption: interaction with other legislation - negligible value claims


Paragraph 33 Schedule 7AC TCGA 1992 applies to negligible value claims when a loss on a disposal of the asset that is the subject of the claim at the time of the claim would not have been allowable because of any of the exemptions of the substantial shareholdings exemption regime. It prevents the deemed disposal and reacquisition of an asset that is the consequence of a negligible value claim from being treated as if it occurred before the time of the claim.