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Official guidance
Capital Gains Manual

CG52700P · Shares and securities: company reconstructions and amalgamations: company reconstructions and amalgamations: the shareholder TCGA92/S136

  • CG52700 · Company reconstructions: shareholder: introduction
  • CG52701 · Company reconstructions: shareholder: qualifying conditions
  • CG52702 · Company reconstructions: shareholder: definition of debenture
  • CG52706 · Company reconstructions: shareholder: cancellation or extinction of shares
  • CG52707 · Company reconstructions: scheme of reconstruction, issue of shares, etc. on or after 17 April 2002
  • CG52707A · 1st Condition (Paragraph 2 Sch 5AA): issue of ordinary share capital
  • CG52707B · 2nd condition (paragraph 3 Sch 5AA): Equal entitlement to new shares
  • CG52707C · 3rd Condition (Paragraph 4 Sch 5AA): Continuity of Business
  • CG52707D · 4th condition (Paragraph 5 Sch 5AA): Compromise or arrangement with members
  • CG52709 · Company reconstructions: meaning of business: S136
  • CG52720 · Company reconstructions: shareholder: common examples
  • CG52721 · Company reconstructions: shareholder: demergers
  • CG52722 · Company reconstructions: shareholder: Section 110 Insolvency Act 1986 liquidations
  • CG52723 · Company reconstructions: shareholder: partitions
  • CG52724 · Company reconstructions: shareholder: distributions
  • CG52725 · Company reconstructions: shareholder: Part 26 Companies Act 2006
  • CG52726 · Company reconstructions: shareholder: Investment Trust and Unit Trust reconstructions
  • CG52728 · Company reconstructions: shareholder: unitisation schemes
  • CG52730 · Company reconstructions or amalgamations: position where shares issued before 17 April 2002
  • CG52740 · Company reconstructions: shareholder: effect of TCGA92/S136
  • CG52742 · Company reconstructions: shareholder: computations involving TCGA92/S136
  • CG52750 · Company reconstructions: shareholder: anti-avoidance provisions
  • CG52760 · Company reconstructions: shareholder: TCGA92/S136: introduction
  • CG52766 · Company reconstructions: TCGA92/S137 prevents TCGA92/S136 from applying
  • CG52767 · Company reconstructions: shareholder: TCGA92/S136 disapplied: tax unpaid
  1. Shares and securities: company reconstructions and amalgamations: company reconstructions and amalgamations: the shareholder TCGA92/S136: contents
  2. Company reconstructions: shareholder: unitisation schemes

CG52728 | Company reconstructions: shareholder: unitisation schemes

From HM Revenue & Customs · Capital Gains Manual

A unitisation scheme is a particular type of reconstruction or amalgamation. In a unitisation the shares and securities held by a private investment company are transferred to an authorised unit trust. The unit trust then issues units to the shareholders in proportion to their shareholdings. A transfer may be made to a number of different unit trusts under the same management. TCGA92/S136 applies to the issue of the units.

TCGA92/S139 does not apply to the transfer of the shares and securities to the unit trust because of TCGA92/S139 (4), see CG52819.

Most major unit trust managers offer this type of scheme. Typically the original company will be an old family trading company whose business has been sold and the proceeds invested. Over the years the shareholdings have been diluted as the shares pass down through the generations. The present members do not want to manage the investment portfolio themselves. Therefore, they are happy to transfer the shares to the unit trust.

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