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