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Back to basics: Depreciatory transactions & value shifting

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This guide considers two anti-avoidance provisions – concerning depreciatory transactions and value shifitng – which should be considered whenever a company is sold out of a capital gains group. The depreciatory transaction rules can only adjust a loss. They may eliminate a loss but cannot turn it into a gain. The rules may be invoked where an asset is transferred at no gain /no loss prior to a sale of a subsidiary or where there is a dividend strip prior to sale. Value shifting adjustments can decrease a loss, turn a loss into a gain or increase a gain. Value shifting may apply where assets are transferred at below market value and cost or dividends are paid out of manufactured profits prior to the sale.

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