SVM119020 | Other compliance matters: value shifting

When value is shifted out of shares owned by either a controlling shareholder or a person connected with them and into other shares, the value shifting rules in section 29 TCGA 1992 should be considered - and the transaction is treated as a disposal for CGT purposes. See CG13200.

Example:

A controlling shareholder has 75 shares. Their son has 25 shares. The controlling shareholder redesignates their 75 shares as preference shares, thereby shifting value into the 25 shares which are now the only ordinary shares in the company.

Additional Guidance: SVM150000