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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Value shifting: two or more persons exercising control

The question of whether TCGA92/S29 (2) applies where two or more persons exercise control of a company was considered in the case of Floor v Davis 52TC609. This established

  • the word `person’ in TCGA92/S29 (2) includes two or more persons who join together to exercise control of the company
  • it is not necessary for those persons to have all voted in favour of the company resolution which resulted in the transfer of value, or
  • to have attended the company meeting at which that resolution was discussed.