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Contents

Official guidance
Capital Gains Manual

CG47020P · Capital Gains Manual: Companies and Groups of Companies: Groups of companies: Anti-loss buying rules in Finance Act 2006

  • CG47020 · New anti-loss buying rules in FA 2006 - general
  • CG47021 · Targeted anti-loss buying rule - interaction with Schedule 7A
  • CG47023 · Targeted anti-loss buying rule - definition of change of ownership
  • CG47024 · Targeted anti-loss buying rule - definition of arrangements
  • CG47025 · Targeted anti-loss buying rule - definition of tax advantage
  • CG47026 · Targeted anti-loss buying rule - is a tax advantage a main purpose?
  • CG47027 · Targeted anti-loss buying rule - tax advantage - choice of commercial options
  • CG47029 · Targeted anti-loss buying rule - choice of commercial options
  • CG47030 · Targeted anti-loss buying rule - interaction with deemed no gain/no loss disposals
  • CG47031 · Targeted anti-loss buying rule - effect of the legislation
  • CG47032 · Targeted anti-loss buying rule - definition of pre-change asset
  • CG47033 · Targeted anti-loss buying rule - asset no longer regarded as a pre-change asset
  • CG47033A · Targeted anti-loss buying rule - continuity of the rules
  • CG47034 · Targeted anti-loss buying rule - time of loss accrual and company to which tax advantage arises
  • CG47035 · Targeted anti-loss buying rule - limited exception to the rule for gain assets held before change of ownership
  • CG47036 · Targeted anti-loss buying rule - interaction of FA 2006 legislation with pre-existing losses
  • CG47037 · Targeted anti-loss buying rule - example 1
  • CG47038 · Targeted anti-loss buying rule - example 2
  • CG47039 · Targeted anti-loss buying rule - example 3
  • CG47040 · Targeted anti-loss buying rule - commencement
  • CG47045 · Targeted anti-loss buying rule - special rules for pooled securities
  • CG47051 · Targeted anti-loss buying rule - interaction with targeted anti-loss creation rule
  • CG47052 · Targeted anti-loss buying rule - interaction with targeted anti-loss creation rule - example
  • CG47028 · Targeted anti-loss buying rule - tax advantage - choice of commercial options
  • CG47033B · Targeted anti-loss buying rule - continuity of the rules
  • CG47046 · Targeted anti-loss buying rule - special rules for pooled securities
  1. Capital Gains Manual: Companies and Groups of Companies: Groups of companies: Anti-loss buying rules in Finance Act 2006: Contents
  2. Targeted anti-loss buying rule - commencement

CG47040 | Targeted anti-loss buying rule - commencement

From HM Revenue & Customs · Capital Gains Manual

The new provisions in TCGA92/S184A to F apply where a tax advantage arises on or after 5 December 2005. This can include situations where a loss arose prior to 5 December, but where the gain that it might otherwise have reduced arises on or after that date.

As explained at CG47034, TCGA92/S184A to F take effect whether or not the loss arises before, at the same time as, or after, the change of ownership, and whether or not there is a chargeable gain from which it may be deducted at that time.

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