This section applies where, on a conversion of securities, a person receives, or becomes entitled to receive, any sum of money ("the premium") which is by way of consideration (in addition to his new holding) for the disposal of the converted securities.
If ... the premium is small, as compared with the value of the converted securities, ...—
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Where the allowable expenditure is less than the premium (or is nil)—
In subsection (4) above "allowable expenditure" means expenditure which immediately before the conversion was attributable to the converted securities under paragraphs (a) and (b) of section 38(1).