Corporation tax on capital gains – scheme to generate a capital loss in reliance on the
identification rules for matching a disposal of shares with an acquisition under s 106 TCGA
1992 – value shifting rules in s 30 TCGA 1992 – application of s 30(9) notwithstanding that
the shares were owned at the time of the disposal, where disposal and acquisition form part
of the scheme which engages s 30 – whether, in the alternative, the disposal and acquisition
for the purposes of s 30(9) is determined by the computational rules required by s 106 –
Davies v Hicks applied – application of s 30(5) to eliminate the capital loss.