CG46800 - Value shifting: outline for groups: scope of value shifting charge

TCGA92/S30, TCGA92/S31, TCGA92/S32 & TCGA92/S33

TCGA92/S30 provides for the consideration for a disposal to be increased by a just and reasonable amount where a scheme or arrangements

• materially reduces the value of an asset, and
• gives rise to a tax-free benefit.

General instructions on Section 30 are at CG13260+. Anti-Avoidance Group (Investigation) is responsible for deciding whether Sections 30-34 should apply in any particular case and the amount of the adjustment. Districts are responsible for identifying cases which appear to fall within the scope of these provisions. You should report any such case to Anti-Avoidance Group (Investigation) as soon as it is apparent that the legislation may apply and before you put forward any argument on the point.