The acquiring company may pay cash or give some other consideration as well as issuing shares and debentures. This should be treated as a capital distribution in respect of the original shares, see CG57810+, to which the provisions of TCGAQ92/S128 (3) apply, see CG51875. If the amount of cash is small compared with the value of the original shares the taxpayer may elect to have it treated as a small capital distribution, see CG57835.

Example

January 2005 an individual buys 20,000 £1 ordinary shares in Dirty Denims Ltd at a cost of £3 per share.

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