266 Other types of reconstruction266.1 Basic charge to taxWhere the reconstruction is not a direct demerger, the distribution will count as a capital distribution within Section 122 of the Taxation of Chargeable Gains Act 1992 and therefore, prima facie, the recipient shareholders will be deemed to have disposed of the whole or part of their shares. If the shares which are issued by the transferee company effectively replace all of the shareholders’ shares in Company A, as will be the case with a reconstruction and with most mergers, each shareholder will be treated as disposing
Where the reconstruction is not a direct demerger, the distribution will count as a capital distribution within Section 122 of the Taxation of Chargeable Gains Act 1992 and therefore, prima facie, the recipient shareholders will be deemed to have disposed of the whole or part of their shares. If the shares which are issued by the transferee company effectively replace all of the shareholders’ shares in Company A, as will be the case with a reconstruction and with most mergers, each shareholder will be treated as disposing
**Trials are provided to all LexisPSL and LexisLibrary content, excluding Practice Compliance, Practice Management and Risk and Compliance, subscription packages are tailored to your specific needs. To discuss trialling these LexisPSL services please email customer service via our online form. Free trials are only available to individuals based in the UK. We may terminate this trial at any time or decide not to give a trial, for any reason. Trial includes one question to LexisAsk during the length of the trial.
0330 161 1234