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HMRC internal manual

Capital Gains Manual

Gifts: exchange for shares

On the assumption that Section 162 relief is not available or only partially available a Section 165 claim may be made, provided that the disposal is otherwise than by way of a bargain at arm’s length, including a transaction deemed to be such because it is between connected persons. Under TCGA92/S286 (4) partners are not connected with each other in relation to disposals of partnership assets pursuant to BONA FIDE commercial arrangements.