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HMRC internal manual

Capital Gains Manual

Value shifting: outline of rules for groups: commencement

FA89/S136 (2)

TCGA92/S31 and TCGA92/S32 apply to disposals on or after 14 March 1989, except that no account should be taken of any reduction in the value of a subsidiary attributable to

  • the payment of a dividend caught by Section 31
  • an intra-group disposal of an underlying asset caught by Section 32

unless the payment of the dividend or the intra-group disposal took place on or after 14 March 1989.

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+.