12ZBA refers to "no gain/no loss provisions". These are provisions which deem the disposal to be made at a value that does not give rise to a gain or a loss. (For example, transfers between husband and wife). It does not apply to transactions which merely result in no gain (or no loss).
Don't get me wrong. I don't think the legislations sets out what it intended to do. If a person was not inclined to notify chargeablity as required under existing legislation, adding an additional requirement to notify will not change that. All it is doing is creating a potential penalty position for those who do notify.
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