Commentary

D8.382 Rights issues etc

Corporate tax
Corporate tax | Commentary

D8.382 Rights issues etc

Corporate tax | Commentary

D8.382 Rights issues etc

Rights issues

The rules in TCGA 1992, ss 127–1301 do not apply2 to a company reorganisation in which new shares or debentures are allotted to shareholders in the company in respect of, and in proportion to, their existing holdings3 when:

  1.  

    (a)     investment relief is attributable to the original holding or the allotted shares; and

  2.  

    (b)     if the original holding qualifies for investment relief, those shares have been held continuously4 from the time they were issued until the reorganisation.

In that case, the new shares are treated as a separate holding acquired by the investing company at the

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