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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Assets: principles of valuation: valuation of assets disposed of in series of transactions

Without special legislation connected persons could exploit the market value rule by transferring singly in a series of transactions assets which are worth more together than separately. For example, the entire share capital of a company could be transferred one share at a time. Each share may be worth much less by itself than as part of the entire holding and so the whole of the company could be transferred without gains accruing on the whole of its value.

This way of minimising the value of assets transferred has been countered by legislation which allows a series of transactions to be considered together for valuation purposes (TCGA92/S19 and TCGA92/S20, see CG14650+).