Taxation of Chargeable Gains Act 1992 section 153

Schedule 7AB paragraph 3

Section 153 and Schedule 7AB paragraph 3 deal with the rules governing the restriction of losses on disposals of assets between companies within a group, as amended by Finance Act 2011.

• Where assets are transferred between companies in the same group, any capital loss arising on a subsequent disposal may be restricted to prevent artificial loss creation.
• The restriction applies where the transferee company disposes of an asset that was previously acquired from another group company on a no gain/no loss basis.
• The amendment made by Finance Act 2011 Schedule 10 paragraph 5(c) refined the operation of these loss restriction rules to ensure they function correctly within the updated framework for group capital gains.
• These provisions are designed to prevent groups of companies from generating allowable losses through intra-group transactions that do not reflect genuine economic losses.

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