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Official guidance
Capital Gains Manual

CG51890P · Shares and securities: share reorganisations: apportionment of cost

  • CG51890 · Share reorganisations: apportionment of cost: general
  • CG51892 · Share reorganisations: apportionment of cost: main rule
  • CG51893 · Share reorganisations: apportionment of cost: main rule
  • CG51895 · Share reorganisations: apportionment of cost: example
  • CG51910 · Share reorganisations: apportionment of cost: 1982 holding
  • CG51919 · Share reorganisations: apportionment of cost: different classes of share
  • CG51920 · Reorganisations of share capital: apportioning costs after a bonus issue
  • CG51930 · Reorganisations of share capital: apportioning costs after a rights issue
  • CG51940 · Reorganisations of share capital: apportioning costs within the new holding: 1982 holding
  • CG51965 · Reorganisations of share capital: apportioning costs: listed shares and units in unit trusts
  • CG51976 · Reorganisations of share capital: apportioning costs at the date of reorganisation
  • CG51980 · Reorganisations of share capital: creation of separate holdings
  • CG51981 · Reorganisations of share capital: creation of separate holdings: example using section 130
  • CG51982 · Reorganisations of share capital: creation of separate holdings: apportionment of cost: 1982 holding
  • CG51995 · Reorganisations of share capital: apportionment of cost: analysis of statute
  • CG52000 · Reorganisations of share capital: apportionment of cost under section 130: date of reorganisation
  • CG52002 · Reorganisations of share capital: apportionment of cost under section 130: listings at different times
  • CG52020 · Reorganisations of share capital: apportionment of cost where ‘relevant securities’ involved
  • CG52040 · Reorganisations of share capital: capital distributions treated as consideration for disposal
  • CG52041 · Reorganisations of share capital: partly-paid shares issued
  • CG52043 · Reorganisations of share capital: apportionment of cost to partly paid shares
  • CG51891 · Share reorganisations: apportionment of cost: general
  • CG51894 · Share reorganisations: apportionment of cost: main rule
  • CG52050 · Reorganisations of share capital: apportioned cost: use of Interactive Data (Extel): adjustment factors
  • CG52052 · Reorganisations of share capital: apportioned cost: use of Interactive Data (Extel): adjustment factors example
  1. Shares and securities: share reorganisations: apportionment of cost: contents
  2. Reorganisations of share capital: apportionment of cost under section 130: listings at different times

CG52002 | Reorganisations of share capital: apportionment of cost under section 130: listings at different times

From HM Revenue & Customs · Capital Gains Manual

TCGA92/S130(1) gives a three month period in which the shares or debentures must achieve a listing. This gives the company time to arrange a listing for new shares or debentures. In the meantime the original shares may continue to be listed. It would defeat the object of Section 130 if the new shares were treated as not listed (so that TCGA92/S129 applied) immediately after the rights issue but they were then listed within the three month time limit (so that section 130 applied). This would impose an unnecessary valuation burden on HMRC and customer alike. Therefore, if the new holding consists of more than one class of listed share or listed debenture, you make the apportionment on the first day, in the three month period, in which all such securities are in fact listed.

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