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HMRC internal manual

Capital Gains Manual

Depreciatory intra-group asset transfers: asset identity rule

Section 32 applies to the intra-group disposal of an underlying asset by the second company at less than market value if the transfer is also at less than the cost to the second company. That is, the company has to realise a commercial loss on the disposal.

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+.