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HMRC internal manual

Capital Gains Manual

Depreciatory intra-group asset transfers: avoidance test

The value shifting rules do not apply if the disposal of the underlying asset is effected for bona fide commercial reasons and does not form part of a scheme or arrangements of which the main purpose, or one of the main purposes, is avoidance of liability to Corporation Tax. The effect of this avoidance test in TCGA92/S32 (2) is that you do not need to consider the market value of assets transferred intra-group which have reduced in value for external commercial reasons and are disposed of at a loss for reasons unconnected with tax planning.

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+.