Currently the Society believes there are important deficiencies in the legislation that will lead to considerable uncertainty. One fundamental reservation is the scope of the loss restriction rules outlined in clause 32. Our submission focuses on this clause.
The Society proposes that clause 32 should be deleted from the bill. The purpose of the amendment is to allow time for consultation on the appropriate scope of the loss restriction rules following a change in ownership and company reconstruction, and any changes required to enable HMRC to counter transactions that seek to avoid the scope of the loss-restriction rules while not adversely affecting transactions that are not the original target of the loss-restriction rules.