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Finance Act 2014

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Finance Act 2014, Section 63 is up to date with all changes known to be in force on or before 04 March 2025. There are changes that may be brought into force at a future date. Changes that have been made appear in the content and are referenced with annotations. Help about Changes to Legislation

63Avoidance involving lossesU.K.
This section has no associated Explanatory Notes

(1)In section 184G of TCGA 1992 (avoidance involving losses: schemes converting income to capital)—

(a)for subsections (2) and (3) substitute—

(2)Condition A is that a receipt or other amount arises to a company directly or indirectly in consequence of, or otherwise in connection with, any arrangements.

(3)Condition B is that—

(a)that amount falls to be taken into account in calculating a chargeable gain (the “relevant gain”) which accrues to a company (“the relevant company”), and

(b)losses accrue (or have accrued) to the relevant company (whether before or after or as part of the arrangements)., and

(b)in subsection (4), for “the receipt” substitute “ the amount mentioned in subsection (2) ”.

(2)In section 184H of that Act (avoidance involving losses: schemes securing deductions)—

(a)in subsection (2)(b), omit “on any disposal of any asset”,

(b)for subsection (3) substitute—

(3)Condition B is that the relevant company, or a company connected with the relevant company, becomes entitled to an income deduction directly or indirectly in consequence of, or otherwise in connection with, the arrangements.,

(c)in subsection (4), for paragraph (a) substitute—

(a)that income deduction, and, and

(d)in subsection (10), after the definition of “arrangements” insert—

income deduction” means—

(a)a deduction in calculating income for corporation tax purposes, or

(b)a deduction from total profits,.

(3)The amendments made by this section have effect—

(a)in relation to arrangements entered into on or after 30 January 2014, and

(b)in relation to arrangements entered into before that date but only to the extent that any chargeable gain accrues on a disposal which occurs on or after that date.

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