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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Depreciatory intra-group asset transfers: liquidations

TCGA92/S32 (5)

The value shifting provisions do not apply on a disposal resulting from a capital distribution in the course of winding up the company which has made the intra-group transfer of the underlying asset. This exclusion is in TCGA92/S32 (5).

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+.