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GC 13: Calculation of arm’s length amounts
or “How to work out fair prices between businesses”
You could also call this:

“Definitions used in rules about tax avoidance and transactions”

In sections GC 6 to GC 13, you need to understand some important words. When you see the word ‘acquisition’, it means getting something or having something available to use. However, it doesn’t include when a company just receives money for selling shares, unless those shares are fixed-rate shares.

The word ‘amount’ in these sections can mean any number, even zero.

‘Supply’ means making something available for others to use. But it doesn’t include when someone pays a company for shares and keeps those shares, unless they are fixed-rate shares.

These definitions help you understand what the law means when it uses these words in the sections about avoiding taxes and dealing with transactions that aren’t at market value.

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Next up: GC 15: Aspects of loan adjusted for application of sections

or “Rules for adjusting international company loans for tax purposes”
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Part G Avoidance and non-market transactions
Market value substituted

GC 14Definitions for sections GC 6 to GC 13

  1. In sections GC 6 to GC 13,—

    acquisition—

    1. includes obtaining the availability of anything; but
      1. does not include the mere receipt or retention by a company of consideration for the issue of a share, unless the share is a fixed-rate share

        amount includes zero

          supply—

          1. includes making anything available; but
            1. does not include the mere payment, and subsequent continuing making available, by a person to a company of consideration for the issue of a share, unless the share is a fixed-rate share.

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