Commentary

C2.708 Bed and breakfast transactions

Capital gains tax
Capital gains tax | Commentary

C2.708 Bed and breakfast transactions

Capital gains tax | Commentary

C2.708 Bed and breakfast transactions

A bed and breakfast transaction is one where a disposal of securities occurs within a specified period of an acquisition of securities of the same class.

The general rules for matching such a disposal are described in C2.706 (for capital gains tax) and in C2.707 (for corporation tax). For corporation tax purposes, the bed and breakfast rules do not apply to disposals after 4 December 20051. For anti-avoidance legislation which replaces those rules after that date, see C1.501.

In Hicks2, there was a scheme to take advantage of the bed and breakfast rules. D transferred securities (with

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