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TCGA92/S184B to F will apply whenever there is a change of ownership of a company that occurs directly or indirectly in consequence of, or in connection with arrangements. Where a main purpose of the arrangements is to secure a tax advantage involving the deduction of a capital loss from any chargeable gains, then that loss may not be deducted from the gains.

Where the rules apply any gains arising on assets owned by a company at the time of its change of ownership will only be capable of being franked by capital losses deriving from assets it held before the change. »Ê¹ÚÌåÓýapp acquiring company or group will not be able to offset its capital losses against gains arising in its new subsidiary.