An obvious route to realising allowable losses, by assigning the debt to a connected person, is blocked by TCGA 1992, s. 251(4). A loss on the disposal of a debt acquired from an original creditor (or his personal representative or legatee) is not allowable for capital gains purposes where:

the person making the disposal and the original creditor are connected persons (see ¶503-800 for the meaning of connected); or

the debt was acquired through a series of purchases through persons all of whom are connected.

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