Commentary

C2.115 Value shifting

Capital gains tax
Capital gains tax | Commentary

C2.115 Value shifting

Capital gains tax | Commentary

C2.115 Value shifting

Certain transactions involving the shifting of value from one asset to another are deemed to be disposals of the assets the value of which is diminished1. There is deemed to be a corresponding acquisition of an interest in the asset.

Where, on the assumption that the transaction was at arm's length, the person making the deemed disposal could have obtained consideration or additional consideration for the disposal, the disposal is treated as not being at arm's length and the consideration is deemed to be the market value of what is acquired2. Since nothing may actually have been acquired

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