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HMRC internal manual

Capital Gains Manual

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

The rules in TCGA92/S32 deal with the case where a group moves an asset into and out of a subsidiary at artificial prices which reduce the value of the subsidiary’s shares. Detailed instructions on Section 32 are at CG46880+.

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+.