867. Value shifting.

HMRC can adjust the consideration received on certain disposals to take account of material reductions in value, thereby reducing a loss realised on the disposal, increasing a gain realised on the disposal, or converting a loss into a gain1. This provision has effect as respects the disposal of an asset if a scheme has been effected or arrangements have been made (whether before or after the disposal) whereby the value of the asset has been materially reduced, and a tax-free benefit has been or will be conferred2.

This power does not have effect for the purposes of corporation tax if