Commentary

C1.336 Other deemed disposals

Capital gains tax
Capital gains tax | Commentary

C1.336 Other deemed disposals

Capital gains tax | Commentary

C1.336 Other deemed disposals

The value shifting provisions treat two other types of transaction as disposals for capital gains tax purposes. In both cases, the consideration passing is treated as the consideration that would have passed between parties acting at arm's length1.

Other aspects of value shifting are discussed in C2.116, D2.352A.

Owner of property becoming lessee

Where the owner of land or of any other property effects a transaction by which he becomes a lessee of the property (as in a sale and lease back) and there is then any adjustment in the terms of the lease (or the grant of

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