CG51820 | Share reorganisations: consideration paid: general
From HM Revenue & Customs · Capital Gains Manual
As a reorganisation is treated as not involving the acquisition of any new shares aspecial rule is required for dealing with any consideration actually paid for the new holding. TCGA92/S128 (1) provides any consideration which is given for the new holding is deemed to have been incurred on the original shares. This is most relevant to rights issues.