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HMRC internal manual

Capital Gains Manual

Depreciatory intra-group dividends: asset identity rule

TCGA92/S33 (6)

There is an asset identity rule in TCGA92/S33 (6) and TCGA92/S33 (9). An asset owned at an earlier time by one company is treated as the same as an asset owned at a later time by the same company or a company in the same group, if the value of the second asset is derived in whole or in part from the first asset. An example of this would be where a lessee has acquired the reversion of a leasehold interest.

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+.