Pre-entry gains and losses
Anti-avoidance provisions
Arrangements, meaning
Assets derived from other assets
Buying losses or gains
Generally
Pooling
Post-21 March 2007 changes
Pre-change assets
Qualifying change of ownership
Reorganisations etc.
Tax advantage, meaning
Transitional provisions
Assets acquired at different times
Generally
Life assurance companies, assets subject to annual deemed disposal
On or after 19 July 2011
Appropriation of trading stock
Assets deriving from other assets
Companies becoming a member of another group
Gains against which losses can be set-off
Generally
Major change in nature of company's trade or business
Order of set-off
Pre-entry assets
Principal company of one group joining another
Qualifying corporate bonds
Two or more companies joining group simultaneously
Pooled assets
Pre-19 July 2011
Connected groups
Generally
Losses realised before entry
Major change in nature of company's trade or business
Order of use losses
Relevant group
Two or more companies joining group simultaneously
Qualifying losses
Restriction of losses
Scope of the legislation
Unrealised losses on entry
Alternative market value basis
Major change in nature of company's business
Meaning pre-entry asset
Nature of pre-entry assets
Pooled asset cost basis
Pre-entry proportion of loss
Restriction on relief
Time apportioned cost basis
Two or more companies joining group simultaneously
