Special rules apply where, before a disposal, there has been a reorganisation of a company's share capital (see 15750) and no new consideration was given for the new holding of shares in order to determine how many shares held after the reorganisation are qualifying, potentially qualifying or excluded shares for investors' relief purposes when they come to be disposed of. The treatment depends on whether the reorganisation is a reorganisation or reduction of a company's share capital (see 15750) or a takeover or reconstruction).

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