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Corporation Tax Act 2010

Section 74: Disposals of new shares

279.This section denies or restricts share loss relief on the disposal of shares which are identified by virtue of section 127 of TCGA with other shares previously held by the investor company, unless certain conditions are met. It is based on section 575(2) and (4) of ICTA.

280.The reference to section 87(3) at the end of subsection (2) makes clear that this section does not apply to an exchange of shares to which section 87(1) applies. See the commentary on section 87 and Change 19 in Annex 1.

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