268 Value shifting provisions

Where a demerger results in different groups of shareholders owning different companies or groups of companies, care needs to be taken to ensure that the values of the resulting shareholdings correspond as nearly as possible to the values of the original shares—otherwise the value shifting provisions in the Taxation of Chargeable Gains Act 1992 may apply1. These anti-avoidance provisions are intended to prevent a person who has control of a company exercising that control in such a way that value passes out of his shares in, or other rights over, the company, into other shares in,

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