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:
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(a)ÌýÌýÌýÌý 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
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