S455 has now been repealed by F(No.2)A15 for schemes effected on or after 18 November 2015. It is succeed by the {regime anti-avoidance rule CFM38600}.

Some companies seek artificially to shelter profits on their loan relationships (and derivative contracts – CFM56100) by transferring them to other companies in exchange for the issue of shares. It is claimed under GAAP that the transferor is not required to recognise any accounting profit. This is despite the fact that the shares obtained are fully marketable and are capable of being realised for the same cash value at which the loan relationship could have been sold.

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