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HMRC internal manual

Capital Gains Manual

Demergers: indirect demergers: CGT treatment: individuals

In the case of an indirect demerger, the relieving provisions of TCGA92/S192 described in CG33920 do not apply. However transactions including the issue of shares by the transferee company normally amount to a `reconstruction’ within TCGA92/S136. Section 136 provides for the roll-over of the gain that would otherwise arise to the shareholders.