Were it not for the special rules below, it would be possible for gains accruing on securities to be permanently deferred on a reorganisation, reconstruction, conversion, etc. by virtue of provisions rolling them into the replacement assets (see ¶560-500ff, ¶560-800ff. and ¶561-000ff.), in this case qualifying corporate bonds (QCBs) which are then exempt (see ¶559-000). Similar considerations apply to the receipt of gilts issued on the compulsory acquisition of securities (see ¶560-900).

The special rules apply in such cases, where either (TCGA 1992, s. 116(1)):

(1)the original shares are (or include) QCBs and the new holding does not; or

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