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CG52767 | Company reconstructions: shareholder: TCGA92/S136 disapplied: tax unpaid

From HM Revenue & Customs · Capital Gains Manual

The guidance at CG52670 applies if

  • TCGA92/S137 has prevented TCGA92/S136 from applying and

  • the tax on the disposal is unpaid for six months and

  • the new shares or debentures have been transferred to a spouse or civil partner of the transferee or to a member of the same group of companies.