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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
, see all updates

Small capital distributions:


The test whether a capital distribution is small has to be applied to each shareholding. In the case of quoted companies it is likely that the value per share will be the same for each shareholder. A direction under TCGA92/S122 (2) should usually be made by the Inspector dealing with the company. You should ask Shares and Assets Valuation for a valuation if exceptionally the taxpayer claims the value of their shareholding was affected by the special circumstances rule in TCGA92/S272 (3), see CG59514.