The value shifting rules in respect of the disposal of shares or securities by a company1 apply if there are arrangements whereby the value of the shares or securities, or of another asset owned by a member of the same group as the disposing company, is materially reduced with a main purpose of obtaining a tax advantage, unless the arrangements consist solely of making an exempt distribution (so that paying a normal pre-sale distribution is not caught by this rule2). The rules also apply where the disposal of the shares or securities is before their acquisition, but in such circumstances they also apply where the arrangements result in a material increase
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