Commentary

D1.926 Corporate capital losses anti-avoidance—overview

Corporate tax
Corporate tax | Commentary

D1.926 Corporate capital losses anti-avoidance—overview

Corporate tax | Commentary

D1.926 Corporate capital losses anti-avoidance—overview

Specific provisions apply to prevent the utilisation of accumulated capital losses in ways not intended by the legislation. These provisions are designed to counter the obtaining of tax advantages by:

  1.  

    (i)     the contrived creation of a capital loss (see D1.927); or

  2.  

    (ii)     converting an income profit into a capital gain (see D1.941); or

  3.  

    (iii)     linking a capital gain and an income deduction (see D1.942)

The provisions in (ii) and (iii) above differ from many other anti-avoidance provisions in that they do not come into effect unless HMRC considers that the relevant conditions are satisfied and give

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