Commentary

C3.1326 Investors' relief—effect of corporate reorganisations

Capital gains tax
Capital gains tax | Commentary

C3.1326 Investors' relief—effect of corporate reorganisations

Capital gains tax | Commentary

C3.1326 Investors' relief—effect of corporate reorganisations

There are specific rules within the legislation to deal the effects of corporate reorganisations.

Section 126 reorganisations

Where, before the disposal on which investors' relief is being claimed, there has been a reorganisation within the meaning of TCGA 1992, s 126 (see D6.102) and no consideration is given by the qualifying person claiming the relief, on the subsequent disposal the following rules apply1.

Where a number of the original shares were subscribed for by the qualifying person and held continuously for a period ending immediately before the reorganisation, an appropriate number of shares in the new holding are treated as having been subscribed for and as having been issued on, and held continuously from, the same date as those original shares. The number of shares so treated is found by multiplying the total number of shares in the new holding immediately after the reorganisation by the number of original shares subscribed for, issued and held, divided by the total number of original shares. Thus the new holding of shares after the reorganisation is

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