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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Depreciatory intra-group dividends: asset transaction test

In the example in CG46820 the asset transaction is the sale of the underlying valuable asset by Q to R for £70M at Stage 1. This disposal is at no gain/no loss for capital gains purposes under TCGA92/S171 (1), and is accordingly caught by Section 31(6).

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+.