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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Value shifting: relevant assets: depreciatory transactions legislation

FA89/S135 (1) eliminated this loophole, for disposals on or after 14 March 1989, by extending the value shifting provisions where a company disposes of shares in, or securities of, another company. In such a case the value shifting rules cover a reduction in value, not only of the asset disposed of, but of any `relevant asset’, as defined by TCGA92/S30 (2). An asset is a relevant asset if, at the time of the disposal to which TCGA92/S30 applies, it is owned by a company in the same group as the company making 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+.