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HMRC internal manual

Capital Gains Manual

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

Exploitation of the exclusion for group dividends using the drain out dividend scheme, see CG46820, led to the extension of the value shifting rules for groups of companies in FA89/S135 - FA89/S137. These changes took effect on 14 March 1989. Further amendments were made in FA 1999, with effect from 9March 1999. FA2000/SCH29/PARA1 introduced changes to the definition of a group, removing the residence requirement for group membership. For disposals on or after 1 April 2000, the group for the purposes of these provisions is not limited to companies resident in the UK.

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+.