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Section 151BC: CITR: company reconstructions etc

Taxation of Chargeable Gains Act 1992 · 1992 c. 12View on legislation.gov.uk

Part IV: Shares, securities, options etc. — Chapter III: Miscellaneous provisions relating to commodities, futures, options and other securities

If—

an individual or company ("the investor") holds shares in or debentures of a company ("company A"),
there is a reconstruction or amalgamation affecting that holding ("the existing holding"),
immediately before the reconstruction or amalgamation, CITR is attributable to the shares or debentures included in the existing holding in respect of one or more years of assessment or accounting periods, and
the shares or debentures included in the existing holding have been held by the investor continuously from the time they were issued until the reconstruction or amalgamation,

sections 135 and 136 (share exchanges and company reconstructions) do not apply in respect of the existing holding.

Subsection (1)(a) applies only if the shares or debentures are held by the investor in the same capacity.

For the purposes of subsection (1) a "reconstruction or amalgamation" means an issue by a company of shares in or debentures of that company in exchange for or in respect of shares in or debentures of company A.

The following provisions of this Act have effect subject to this section—

  • section 116 (reorganisations, conversions and reconstructions),

  • Chapter 2 of Part 4 (reorganisation of share capital, conversion of securities etc).

The investor is treated as disposing of any securities or shares which but for subsection (1) the investor—

would be treated as exchanging for other securities or shares by virtue of section 136, or
would be so treated but for section 137(1) (which restricts section 136 to genuine reconstructions).

About this text

This legislation text comes from legislation.gov.uk. Contains public sector information licensed under the Open Government Licence v3.0. These source and reuse terms cover the legislation text, not Remedy's commentary.

Reuse reviewed 21 August 2026 under Open Government Licence v3.0.