There are provisions to apportion the ‘base cost’ (¶519-500) of an asset where, on a merger, division or metamorphosis, another asset in the same ownership derives its value from that asset (TCGA 1992, s. 43).

Such apportionment also applies where the following subsist (TCGA 1992, s. 43):

rights or interests in or over an asset have been created so as to effectively produce, in the same ownership, a separate asset alongside the original asset which derives its value from the original asset; or

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