SAIM7120 - Artificial transactions in futures and options: losses (this guidance applies to disposals of futures and options before 6 April 2013)
Losses are relievable against profits from miscellaneous transactions
ITTOIA05/S567 gives rules on losses, when they arise and how they are relievable.
Firstly, losses are only relievable where ITA07/S152 applies. This gives loss relief for miscellaneous transactions, where profits on those transactions would be taxable. »Ê¹ÚÌåÓýapp loss is only relievable against profits from other miscellaneous income. (This is essentially the same as the relief for losses under Case VI of Schedule D formerly at ICTA88/S392.) Miscellaneous income is listed in ITA07/S1016 and includes income chargeable under ITTOIA05/PT4/CH12. »Ê¹ÚÌåÓýapp loss is taken to arise when the disposal is made.
No double counting
Secondly, there is a link to TCGA92/S148A to S148C, which is relevant for the application of the rules in ITTOIA05/S564 (SAIM7110). »Ê¹ÚÌåÓýappse three sections were inserted into TCGA as a consequence of the rewriting of ICTA88/SCH5AA (the predecessor legislation to ITTOIA05/PT4/CH12). As described in SAIM7110, they prevent gains and losses which have been taxed or relieved under Chapter 12 from being taxed or relieved again under the capital gains rules.