Commentary

D7.447 Equities—'bed and breakfast' transactions

Corporate tax
Corporate tax | Commentary

D7.447 Equities—'bed and breakfast' transactions

Corporate tax | Commentary

D7.447 Equities—'bed and breakfast' transactions

The general provisions for bed and breakfast transactions (TCGA 1992, ss 105–106A) in which shares are sold and reacquired shortly afterwards are discussed in C2.708. A similar but slightly modified rule applies for shares and certain other assets held by life insurance companies1.

The rules apply to any security within the meaning of FA 2012, ss 119 or 120 (share pooling rules for life insurance companies) and look both forward and back ten days matching the general identification rules in TCGA 1992, s 107 (see C2.701, D1.920).

Unlike the general rules however, those applicable to life insurance

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