A popular area on groups which tax examiners love is the targeted anti-avoidance rules (TAAR) to prevent companies buying other companies to use up their pre-acquisition losses.

Blue Plc buys Orange Plc. Orange has pre-acquisition losses.

TAAR prevents Orange property and intangible losses from being refreshed.

If there is a major change in nature or conduct of trade (MCINOCOT) in Orange within a period of 5 years, then the pre-acquisition trading losses cannot be carried forward to the period of new ownership.

Companies in the Blue Plc group cannot access any of Blue Plc’s pre-acquisition capital losses.

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