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True value

28 July 2009
Issue: 4216 / Categories: Forum & Feedback , Admin , Capital Gains
Rights have been disposed of to a connected person for no consideration. Does this transaction and the valuation need to be declared to HMRC?

We act for a client who has disposed of certain rights to a connected person.

That part is not in doubt – the connection.

Both parties value the rights at nil and no consideration will change hands. I have read TCGA 1992 s 3A very carefully and (I think) all that flows from it but nowhere can I find whether our client is covered by s 3A and thus does not need to disclose that a subjective albeit honest and fair valuation of the rights has been used so to speak to arrive at a figure below the reporting limits.

I have trawled through HMRC’s Tax Return Guide Simon’s Taxes the Yellow Tax Handbook and everything else I can lay my hands on but nowhere can I find anything that tells me that it’s not that...

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