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IFM37760 | Accruals basis elections: anti-avoidance

From HM Revenue & Customs · Investment Funds Manual

TCGA92/S103KFE contains an anti-avoidance provision. The provision applies where the main or one of the main purposes of making an election is to secure that an allowable loss can be created under TCGA92/S103KFD and provides for adjustments to be made to counteract the loss to ensure that it is not effective.