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The legislation contains a number of provisions designed to ensure that relief is given in respect of a fall in the value of shares or securities only so far as the fall in value results from a change in market conditions, and that as between the date of the chargeable transfer and the relevant date like is compared with like. The provisions relate to capital payments and calls (reverse sides of the same coin) and to corporate reorganisations to which TCGA 1992, s 127 applies.

If the property transferred by the lifetime transfer consists of shares or securities ¹ and at any time before the relevant date, ie, the date of the transferor's death or the earlier disposal of the property, the transferee or his spouse or civil partner becomes entitled to a capital payment in respect of them, then for the purposes of the relief the market value of the transferred property on the relevant date is treated as increased by an amount equal to that payment². This prevents the