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Contents

Official guidance
Capital Gains Manual

CG47320P · Capital Gains Manual: Companies and Groups of Companies: Groups of companies: Anti-gain buying rules in Finance Act 2006

  • CG47320 · Anti-gain buying rules in FA 2006 - general
  • CG47321 · Targeted anti-gain buying rule - general
  • CG47323 · Targeted anti-gain buying rule - definition of change of ownership
  • CG47324 · Targeted anti-gain buying rule - definition of arrangements
  • CG47325 · Targeted anti-gain buying rule - definition of tax advantage
  • CG47326 · Targeted anti-gain buying rule - is a tax advantage a main purpose?
  • CG47327 · Targeted anti-gain buying rule - tax advantage - choice of commercial options
  • CG47331 · Targeted anti-gain buying rule - effect of the new legislation
  • CG47332 · Targeted anti-gain buying rule - definition of pre-change asset
  • CG47333 · Targeted anti-gain buying rule - asset no longer regarded as a pre-change asset
  • CG47334 · Targeted anti-gain buying rule - time of loss accrual and company to which tax advantage arises
  • CG47335 · Targeted anti-gain buying rule - limited exception to the rule for gain assets held before change of ownership
  • CG47336 · Targeted anti-gain buying rule - interaction of legislation with pre-existing losses
  • CG47337 · Targeted anti-gain buying rule - example
  • CG47338 · Targeted anti-gain buying rule - commencement
  • CG47322 · Targeted anti-gain buying rule - general
  • CG47328 · Targeted anti-gain buying rule - tax advantage - choice of commercial options
  • CG47329 · Targeted anti-gain buying rule - choice of commercial options
  1. Capital Gains Manual: Companies and Groups of Companies: Groups of companies: Anti-gain buying rules in Finance Act 2006: Contents
  2. Targeted anti-gain buying rule - commencement

CG47338 | Targeted anti-gain buying rule - commencement

From HM Revenue & Customs · Capital Gains Manual

The 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 in CG47334, TCGA92/S184B to F take effect whether or not the gain arises before, at the same time as or after the change of ownership, and whether or not there is an allowable loss which can be set against the gain at that time.

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