What is value shifting
Operates where a person who has controlover a company excerses their control so that value passes out of their own shares in to other shares in the company
Treated as a part disposal for CGT purposes
What are the deemed proceeds
Value that transfers into the new shares
Proceeds = Dads shareholding * difference in value
Minus any costs for the son
What is the cost
Orginal cost * Proceeds / Proceeds + Value of dads new shareholding