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HMRC internal manual

Capital Gains Manual

Value shifting: outline for groups: scope of value shifting charge

TCGA92/S30, TCGA92/S31, TCGA92/S32 & TCGA92/S33

TCGA92/S30 provides for the consideration for a disposal to be increased by a just and reasonable amount where a scheme or arrangements

  • materially reduces the value of an asset, and
  • gives rise to a tax-free benefit.

General instructions on Section 30 are at CG13260+

Finance Act 2011 introduced a new Targeted Anti-Avoidance Rule for disposals of shares and securities by companies on or after 19 July 2011. See CG48500+.