CG14560 - Transactions between connected persons

TCGA92/S18

Where the person who acquires an asset is connected with the person making the disposal, see CG14580, they are to be treated as parties to a transaction otherwise than by way of bargain at arm’s length. This brings the market value rule in TCGA92/S17 into operation. In addition TCGA92/S18 provides that any loss on the transaction becomes a ‘clogged loss’.