817. Transactions between connected persons.

Where a person acquires an asset and the person making the disposal is connected1 with him, the acquisition and disposal are treated as a transaction otherwise than by way of a bargain made at arm's length2, with the result that the consideration for the disposal is deemed to be equal to the market value of the asset3.

If the asset acquired from the connected person is subject to any right or restriction enforceable by the person making the disposal, or by a person connected with him, the market value of the asset4 is taken to be:


    (1)     what its market