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The value shifting rules¹ are anti-avoidance provisions without which it would be possible for value to be shifted (from one asset to another) or extracted in some way without triggering a tax charge on the value shifted or extracted². This could result in allowable losses being artificially inflated or chargeable gains artificially reduced when there is a disposal of the asset whose value has been artificially reduced.

There are three value shifting rules³:

1. Ìý

   •ÌýÌýÌýÌý the general provisions where value has shifted from one asset to another in certain circumstances (see C2.115)

2. Ìý

   •ÌýÌýÌýÌý the tax-free benefits rules (see below)

3. Ìý

   •ÌýÌýÌýÌý disposal of shares or securities by a company (see D2.352A)⁴

Other value shifting-type anti-avoidance rules include the close company asset transfer rules in TCGA 1992, s 125 (see D1.919) and the depreciatory transactions within group companies rules in TCGA 1992, s 176 (see D2.350).