Related Commentary  Related CasesRelated HMRC Manuals

127   Subject to sections 128 to 130, a reorganisation shall not be treated as involving any disposal of the original shares or any acquisition of the new holding or any part of it, but the original shares (taken as a single asset) and the new holding (taken as a single asset) shall be treated as the same asset acquired as the original shares were acquired.

Derivation

CGTA 1979, s. 78.

Cross references

S. 34: circumstances in which value shifting provisions override application of s. 135 and 136 to a reorganisation involving an exchange of shares in or debentures of a subsidiary company with those of a non-group member.

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