Taxation of Chargeable Gains Act 1992 Schedule A1 paragraph 12

Periods of share ownership not to count in a case of value shifting

Paragraph 12 of Schedule A1 deals with the restriction on taper relief where value shifting arrangements have been used to manipulate the period of share ownership.

• Where value has been shifted into shares through a scheme or arrangement, the period of ownership before the value shifting took place may be disregarded for taper relief purposes.
• This prevents taxpayers from artificially benefiting from a longer holding period by shifting value into shares they have held for a considerable time.
• The rule ensures that taper relief is calculated only by reference to the period during which the taxpayer genuinely held the value that gives rise to the chargeable gain.
• This provision was part of the anti-avoidance framework supporting the taper relief regime, which was itself abolished for disposals on or after 6 April 2008 by Finance Act 2008.