CG13282 - Value shifting: TCGA92 S30: compensating reduction

The value shifting rules provide for a compensating reduction of consideration where

  • the consideration for the disposal of an asset is increased under Section 30(5)

and

  • the tax-free benefit giving rise to the Section 30(5) adjustment is an increase in the value of another asset

and

  • there is a disposal of that other asset after the increase in its value.

In such a case the consideration for the disposal of the other asset may be reduced by a just and reasonable amount, TCGA92/S30 (6). You should send to Anti-Avoidance Group (Investigation) any case where the taxpayer requests a compensating adjustment under Section 30(6).