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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
Updated
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Group share exchanges: exchanges of shares for QCBs

The interaction between TCGA92/S116 and TCGA92/S171 (1) first became a practical issue with the introduction of the FOREX legislation. Before the FOREX rules took effect, a security issued by one company to another member of the same group could not be a QCB except in relation to a disposal by a person outside the group, see CG53747. The QCB definition was extended to intra-group issues of foreign currency securities by the FOREX rule in paragraph5 Schedule17 FA1993, see CG53776+. And the QCB definition was extended to cover most intra-group issues of debt by the loan relationships legislation in FA1996, see CG54000+.