Commentary

D6.224 Bonus issue—disposal: apportionment of base cost where more than one class of shares

Corporate tax
Corporate tax | Commentary

D6.224 Bonus issue—disposal: apportionment of base cost where more than one class of shares

Corporate tax | Commentary

D6.224 Bonus issue—disposal: apportionment of base cost where more than one class of shares

Where the new holding includes more than one class of shares or debentures; the method of apportionment differs according to whether the new holding includes any listed shares or securities.

Broadly, if the shares or debentures are unquoted, the apportionment is made by reference to the market value at the date of the later disposal which occasions the computation. However, if any of the shares or debentures are quoted, the apportionment is made by reference to the market values at the date of the reorganisation. This gives the shareholder the advantage of knowing the base cost of their share before any disposal.

These apportionment rules apply equally to shares acquired by way of a rights issue (see D6.232). The amount paid on the rights issue is treated as having been given for the original shares and is added to the cost of the original shares, with the total apportioned over the new holding.

New holding contains listed shares

If any one of the shares, debentures etc of the new holding had a listed market value, the cost of the new holding is apportioned by reference to the listed market value.

This apportionment takes place if the shares etc are listed on a recognised stock exchange (or a daily price published by the managers of the scheme in the case of unit trusts) within three months of the date that the reorganisation took effect (or such longer period as the Board

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