Commentary

D2.352A Group capital gains—Value shifting on disposal of shares or securities

Corporate tax
Corporate tax | Commentary

D2.352A Group capital gains—Value shifting on disposal of shares or securities

Corporate tax | Commentary

D2.352A Group capital gains—Value shifting on disposal of shares or securities

The value shifting rules in respect of the disposal of shares or securities by a company1 apply if there are arrangements whereby the value of the shares or securities, or of another asset owned by a member of the same group as the disposing company, is materially reduced with a main purpose of obtaining a tax advantage, unless the arrangements consist solely of making an exempt distribution (so that paying a normal pre-sale distribution is not caught by this rule2). The rules also apply where the disposal of the

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