This case is about the taxation of capital gains of groups of companies under the Taxation of Chargeable Gains Act 1992 (the 1992 Act). The appeal turns on the construction of section 177A of and Schedule 7A to the 1992 Act. Those provisions place restrictions on the set-off of ‘pre-entry losses.’ They were inserted in the 1992 Act by section 88 of the Finance Act 1993.
Citations:
[2009] EWCA Civ 177, [2009] BTC 114, [2009] STI 689, [2009] STC 980
Links:
Statutes:
Taxation of Chargeable Gains Act 1992
Jurisdiction:
England and Wales
Capital Gains Tax
Updated: 09 December 2022; Ref: scu.317977