Page 124 - P6 Slide - Taxation - Lecture Day 1

Anti-avoidance (par 39) Disposal to connected person

at capital loss

• Ring-fence capital loss if disposed of to –

• –Connected person, or

• –Person who is a member of the same group

of companies

• •Ring-fenced capital losses deductible from

subsequent capital gains made from

disposals to that same person, if still a

connected person

124