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HMRC internal manual

Capital Gains Manual

Value shifting: TCGA92 S30: tax-free benefit

A benefit arises whenever

  • a person becomes entitled to any money or money’s worth
  • the value of an asset increases
  • a liability is reduced or cancelled.

A benefit is tax-free unless, at the time it arises, it is brought into account in computing the recipient`s income, profits or gains for tax purposes, TCGA92/S30 (3).

In considering whether Section 30 restricts a loss claimed under CTA10/S69 or ITA/S131 (relief against income for losses on unquoted shares in trading companies, see VCM70000+ and VCM77000+), the obtaining of loss relief should be regarded as a tax-free benefit.

The value shifting rules apply where the tax-free benefit arises to

  • the person making the disposal
  • a person connected with the person making the disposal, see CG14580+
  • any other person, unless (for this category only) tax avoidance was not a main purpose of the scheme or arrangements,

TCGA92/S30 (1)(b) and TCGA92/S30 (4).

Finance Act 2011 introduced the amended TCGA92/S31 as Targeted Anti-Avoidance Rule for disposals of shares and securities by companies on or after 19 July 2011. TCGA92/S30 no longer applies to such disposals. See CG48500+.