CG52767 | Company reconstructions: shareholder: TCGA92/S136 disapplied: tax unpaid
From HM Revenue & Customs · Capital Gains Manual
TCGA92/S136
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.