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HMRC internal manual

Company Taxation Manual

Particular topics: transactions in securities: interaction with CGT

When a tax advantage is obtained in circumstances C D & E this avoidance legislation applies to the whole of the consideration received, irrespective of any CGT/CT liability incurred by the person in returning the proceeds as capital receipts. In practice the legislation will not normally be invoked unless the tax advantage to be cancelled significantly exceeds the CGT/CT liability paid on the same consideration returned as capital receipts which by concession will be given as a credit against the amount assessed by counteraction.