Section 63 — Finance Act 2014: Avoidance involving losses

Avoidance involving losses 63 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.