SCHEDULE 9 Value Shifting

SCHEDULE 9 Value Shifting

Section 44

Amendments of TCGA 1992

1

In section 30 of TCGA 1992 (tax-free benefits)—

(a)     in subsection (1)(a) omit “or a relevant assetâ€,

(b)     for subsection (2) substitute—

“(2)     But, for the purposes of corporation tax, this section does not have effect if the disposal of the asset is a disposal by a company of shares in, or securities of, another company (as to which see section 31).â€, and

(c)     omit subsection (8).

2

For sections 31 to 34 of TCGA 1992 (which make provision about disposals by companies of shares in or securities of other companies) substitute—

“31 Disposal of shares or securities by a company

(1)     For the purposes of corporation tax, subsection (2) has effect as respects the disposal by a company (“the disposing companyâ€) of shares in, or securities of, another company if—

(a)     arrangements have been made whereby the value of those shares or securities, or any relevant asset, is materially reduced,

(b)     the main purpose, or one of the main purposes, of the arrangements is to obtain a tax advantage, and

(c)     the arrangements do not consist solely of the making of an exempt

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