| Commentary

64.2 Value shifting

| Commentary

64.2 Value shifting

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, because any discrepancy may fall foul of the value-shifting provisions in Sections 29 to 34 of the Taxation of Chargeable Gains Act 1992. The 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

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