No relief is given in certain circumstances where a person makes a loss in a UK or overseas property business and where there are relevant tax avoidance arrangements (ITA 2007, s. 127A). More specifically, the restrictions apply where:

a person makes a loss (whether in partnership or not) in a UK property business or an overseas property business;

the loss has a capital allowances connection (see below); and

the loss arises directly or indirectly in consequence of, or otherwise in connection with, relevant tax avoidance arrangements (again, see below).

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