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HMRC internal manual

Capital Gains Manual

Value shifting: relevant assets: depreciatory transactions legislation

The extension to relevant assets only applies if the following conditions are satisfied.

  • During the period beginning when the relevant asset was depreciated and ending with the Section 30 disposal, the relevant asset has not been the subject of a disposal, other than a disposal at no gain/no loss under TCGA92/S171 (1), or of a deemed disposal under the degrouping provisions in TCGA92/S178 and TCGA92/S179. For this purpose TCGA92/S33 (2) disregards disposals of part of the asset.
  • Assuming that all other circumstances had been the same, except that the relevant asset had not been depreciated, the value of the asset disposed of would have been materially greater.

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+.