Commentary

E1.538 Identification of shares after reorganisation

Personal and employment tax

E1.538 Identification of shares after reorganisation

E1.538 Identification of shares after reorganisation

ITTOIA 2005, s 712 sets out the rules governing the identification of shares following a reorganisation. These rules apply if the new shares are treated as the same assets as the old shares for the purposes of TCGA 1992, ss 126–140L (Pt IV, Ch II)1.

If the old shares satisfied the annual acquisition limit condition, and, if applicable, the condition on acquisition for genuine commercial reasons, the new shares are treated as doing the same2.

However, if only some of the old shares met those conditions, an apportionment is necessary in order to determine the proportion

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