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Home / Simons-Taxes /Corporate tax /Part D2 Groups of companies /Division D2.4 Pre-entry capital gains and losses /Pre-entry capital losses—generally / D2.401 Use of pre-entry capital losses—overview

D2.401 Use of pre-entry capital losses—overview

Corporate tax

For updates affecting this Division please see Part D0 Updates

Pre-entry capital losses—generally

D2.401 Use of pre-entry capital losses—overview

The flexibility available to group companies when transferring assets between them in order to maximise the use of capital losses against group gains could be open to abuse. Specific provisions have been enacted which prevent groups of companies avoiding tax by buying companies

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E5.607 Corporate members

E4.507S Operation of the charge on securities with artificially enhanced market value

C1.106 Allowable capital losses

D1.8101 Groups of companies

B4.130 Summary of OECD guidelines on arm's length principle

B2.218 Surplus business accommodation

I7.504 Designation for the conditional exemption

E4.11120 Additional annual returns by employers—overview

B5.123 BPS—negligible value claims

E1.1502 Tax treatment of transfers with accrued interest

D2.250 Group relief—limited rights, variable rights and options attaching to ordinary shares

C2.902 Wasting assets—wasting of allowable expenditure

E4.1118 Calculation and payment of tax due on retrospective income

I7.120A BPR and excepted assets

E6.324H Nominated income and gains and the ordering rules

E4.1167 Payments made after leaving and after issue of form P45

I11.215 IHT accounts—excepted settlements

C2.1173 Interaction of the exemption election regime with other capital gains exemptions

B2.202 Capital receipts

I5.1304 Beneficiary with contingent interest