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R104 – Wash Sale & Equivalent Rules by Country

Wash sale & equivalent rules by country table below.

Updated over 2 weeks ago

Country

Rule / Equivalent

Notes

United States (IRS)

Wash Sale Rule

30-day window before/after sale; applies to “substantially identical” assets. Crypto treatment remains ambiguous

United Kingdom (HMRC)

30-Day Bed and Breakfast Rule

Disposal and repurchase within 30 days are matched together

Canada (CRA)

Superficial Loss Rule

Loss disallowed if repurchased within 30 days and still held

Germany

No Wash Sale Rule

Losses deductible; long-term disposals (>1 year) can be tax-free

Spain

No Specific Wash Sale Rule

General anti-abuse provisions may apply

Italy

No Specific Wash Sale Rule

Losses reportable; anti-avoidance may apply

Ireland

No Specific Wash Sale Rule

Losses allowed; subject to anti-avoidance

India

No Specific Wash Sale Rule

Losses treated as capital gains; evolving legislation

Japan

No Wash Sale Rule

Losses deductible; carryover limits usually 3 years

South Africa

No Specific Wash Sale Rule

Losses deductible if genuine; anti-avoidance may apply

Australia (ATO)

No Formal Wash Sale Rule

ATO can deny losses under anti-avoidance provisions

New Zealand

No Wash Sale Rule

Standard CGT treatment; avoidance rules may apply


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