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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Value shifting: interaction with degrouping charge

TCGA92/S178 (7) & TCGA92/S179 (9)

Where a company ceases to be a member of a group and there is a deemed disposal of shares or securities at market value under TCGA92/S178 or TCGA92/S179 the amount of the notional market value consideration for the deemed disposal may be increased under the value shifting provisions. The relevant increase is the amount of any adjustment which could have been made under the value shifting provisions if the deemed disposal had been an actual disposal. See also CG45466+.

Section 34 was amended in FA 1999 to take account of cases where the new Section 31A applies (see CG46835-6).

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+.