559-600 Reorganisations where the new asset is a QCB
On a reorganisation, etc. (see ¶559-500), where the old asset is a chargeable asset but the new asset is a qualifying corporate bond (QCB), there is deemed not to be a disposal of the old asset but, in broad terms, the gain or loss which would have accrued had there been a disposal at market value is held over until there is a disposal of the QCB itself (TCGA 1992, s. 116(10)).
In more detail, there is calculated the chargeable gain or allowable loss which would have arisen had the old asset been disposed of for its market value at the time of the relevant transaction (TCGA 1992, s. 116(10)(a)). Of any gain, there is deemed to accrue (TCGA 1992, s. 116(10)(b), (c), (12)–(14)):