Where there is a conversion of securities, the person who is entitled to the securities immediately before the conversion is regarded as transferring them on the day of conversion (if there is no actual transfer), but there is no transferee (ITA 2007, s. 621(2)). ‘Conversion’ for these purposes means a conversion within TCGA 1992, s. 132 (ITA 2007, s. 620(7)) and is discussed at ¶561-000ff.

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