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HMRC internal manual

Capital Gains Manual

Value shifting: depreciatory transactions legislation

There may be cases which are within the scope of both the value shifting provisions and the depreciatory transactions legislation in TCGA92/S176 and TCGA92/S177. If the addition to the consideration for the disposal under the value shifting provisions still leaves a capital loss, a further adjustment restricting or eliminating the loss may be appropriate under the depreciatory transactions rules, see CG46500+.

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+.