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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Value shifting: outline for groups: scope of value shifting charge

Before 14 March 1989 the value shifting rules did not apply to the disposal by one company of shares in another company where the reduction in value resulted from

  • the payment of a dividend at a time when both companies were members of the same group
  • the disposal of an asset by the second company at no gain/no loss, under what is now TCGA92/S171 (1), at a time when both companies were members of the same group.

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+.