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Contents

Official guidance
Capital Gains Manual

CG52521P · Shares and securities: company reconstructions and amalgamations: company reconstructions and amalgamations share exchange

  • CG52521 · Share exchange: scope of TCGA92/S135
  • CG52523 · Share exchange: TCGA92/S135: qualifying conditions: general
  • CG52540 · Share exchange: TCGA92/S135: definition of debenture
  • CG52550 · Share exchange: TCGA92/S135: qualifying corporate bonds
  • CG52560 · Share exchange: TCGA92/S135: deferred consideration
  • CG52562 · Company reconstructions: capital gains cost of shares acquired
  • CG52563 · Company reconstructions: intra-group share exchanges
  • CG52570 · Share exchange: examples
  • CG52579 · Share exchange: examples: effect of TCGA92/S135 and computations
  • CG52582 · Share exchange: effect of TCGA92/S135: pooling
  • CG52583 · Share exchange: effect of TCGA92/S135: computation
  • CG52585 · Share exchange: effect of TCGA92/S135: different classes of shares
  • CG52587 · Share exchange: effect of TCGA92/S135: other consideration received
  • CG52591 · Share exchange: TCGA92/S135: incidental costs
  • CG52594 · Share exchange: TCGA92/S135: 1982 holding
  • CG52610 · Share exchange: anti-avoidance: introduction
  • CG52620 · Share exchange: anti-avoidance: TCGA92/S137
  • CG52631 · Share exchange: anti-avoidance: clearance procedure
  • CG52632 · Share exchange: anti-avoidance: clearance procedure: whether avoidance is a main purpose
  • CG52633 · Share exchange: anti-avoidance: clearance procedure: bona fide commercial reasons
  • CG52636 · Share exchange: anti-avoidance: clearance prevents TCGA92/S137 applying
  • CG52637 · Share exchange: Share exchanges involving non-UK incorporated close companies
  • CG52660 · Share exchange: TCGA92/S135: procedure
  • CG52670 · Share exchange: TCGA92/S135: anti-avoidance provisions apply
  1. Shares and securities: company reconstructions and amalgamations: company reconstructions and amalgamations share exchange: contents
  2. Share exchange: effect of TCGA92/S135: different classes of shares

CG52585 | Share exchange: effect of TCGA92/S135: different classes of shares

From HM Revenue & Customs · Capital Gains Manual

Unquoted shares

If the acquiring company issues different classes of share or debenture it may be necessary to apportion the base cost of the new holding between its different components. The main rule in TCGA92/S129 is that the apportionment is made by reference to the market value of the different shares and debentures at the date of disposal, see CG51892.

Quoted shares

However, TCGA92/S130 will apply if one of the different classes of share or debenture is quoted within three months of the takeover or such later time as the Board may allow, see CG51965. In this case you make the apportionment by reference to market value on the first day on which the new shares or debentures are quoted. For full instructions see CG51965+.

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