Commentary

D1.942 Corporate capital losses anti-avoidance—schemes securing deductions

Corporate tax
Corporate tax | Commentary

D1.942 Corporate capital losses anti-avoidance—schemes securing deductions

Corporate tax | Commentary

D1.942 Corporate capital losses anti-avoidance—schemes securing deductions

The following anti-avoidance provision targets schemes seeking to generate a deduction from income as part of arrangements to crystallise a capital gain against which allowable losses can be set. The provision applies if HMRC considers that four conditions are satisfied and issue a notice to that effect (see D1.943). The conditions are1:

  1.  

    (a)     a company (X) realises or has realised capital losses and as part of any arrangements it realises a chargeable gain; the losses need not have arisen as part of the arrangements2

  2.  

    (b)     the relevant company, or a company connected with

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