Commentary

D6.206 Share for share exchange—qualifying circumstances

Corporate tax
Corporate tax | Commentary

D6.206 Share for share exchange—qualifying circumstances

Corporate tax | Commentary

D6.206 Share for share exchange—qualifying circumstances

The share exchange rules apply where one company ('company B') acquires shares in, or debentures of, another company ('company A') and in exchange issues its own shares or debentures1. The three sets of circumstances where the provisions apply are as follows2:

  1.  

    (a)     Where company B acquires as a result of the exchange, or already holds, over one-quarter of the ordinary share capital of company A3. Ordinary share capital means all the issued shares other than those with a right to a dividend only at a fixed rate4. It also includes units in a unit

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