In a reorganisation, etc. whereby investors are issued with new shares, securities or debentures in respect of their old holding, the new holding (and any of the original holding retained) is generally equated with the original holding (see ¶560-100). However, if the investors are required to give additional consideration for the new holding (either in paying up amounts in respect of retained original holding or to obtain the new securities), this is treated, for some purposes, as given for the original holding (TCGA 1992, s. 128(1)).

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