This section applies for the purposes of corporation tax in respect of chargeable gains if—
at any time ("the relevant time") there is a qualifying change of ownership in relation to a company ("the relevant company") (see section 184C),
a gain (a "qualifying gain") accrues to the relevant company or any other company on a disposal of a pre-change asset (see subsection (3)),
the change of ownership occurs directly or indirectly in consequence of, or otherwise in connection with, any arrangements the main purpose, or one of the main purposes, of which is to secure a tax advantage, and
the advantage involves the deduction of a loss from a qualifying gain (whether or not it also involves anything else).
In the case of a qualifying gain accruing to a company, a loss accruing to the company is not to be deductible from the gain ... .
In this section a "pre-change asset" means an asset which was held by the relevant company before the relevant time (but see also sections 184E and 184F).
In this section "arrangements" includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).
For the purposes of this section it does not matter—
whether a qualifying gain accrues before, after or at the relevant time,
whether a qualifying gain accrues at a time when there are no losses which could be deducted (or could otherwise have been deducted) from the gain, or
whether the tax advantage is secured for the company to which a qualifying gain accrues or for any other company.