Commentary

C1.335 Transfer of value by controlling shareholders

Capital gains tax
Capital gains tax | Commentary

C1.335 Transfer of value by controlling shareholders

Capital gains tax | Commentary

Value shifting

C1.335 Transfer of value by controlling shareholders

A number of transactions by which value passes out of some assets into others are treated as disposals, whether or not there is any actual consideration1.

In practical terms, the most important of these transactions deemed to be disposals relates to the exercise of control of a company by its controlling shareholders2.

If a person controls a company, and exercises his control, eg by alteration of rights, or otherwise, in such a way that the value passes out of shares in the company which are owned by him or a person connected with

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