Commentary

D8.381 Share reorganisations

Corporate tax
Corporate tax | Commentary

D8.381 Share reorganisations

Corporate tax | Commentary

D8.381 Share reorganisations

Special rules1 apply in certain circumstances where there is a reorganisation or reduction2 of the issuing company's share capital to which TCGA 1992, s 116 (concerning reorganisations etc involving qualifying corporate bonds: see D6.111) or s 127 (concerning the 'no disposal rule' which equates an original holding of shares with a new holding of shares that is issued on a reorganisation: see D6.202) applies.

If the investing company holds shares of the same class in the issuing company which it acquired in the same capacity and at different times or in different ways, then, where possible, those shares

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