Where there is a partial division within TCGA 1992 section 140A(1A) or section 140C(1A) there has been a part disposal by the shareholders and/or debenture holders of the shares and/or debentures they hold in the transferor company. Such a chargeable occasion would be contrary to the general principle within the ETMD, see CG45701.

To prevent such an occurrence section 140DA ensures that the ‘rollover’ treatment within section 127 will apply provided that there has been a partial division to which section 140A(1A) applied, see CG45703, or section 140C(1A) applied, see CG45714 and the following conditions are met.

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