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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Groups: indexation allowance restriction: redeemable preference shares

TCGA92/S183 (2)

The definition of `redeemable preference shares’ is set out in CG46140. The provisions which apply to restrict indexation allowance in the case of a debt on a security could not be applied directly to redeemable preference shares because of the pooling rules. The shares which constitute a single holding may have been acquired at various times, before and after the companies became linked. TCGA92/S183 (2) accordingly makes a just and reasonable reduction of the indexation on the disposal. The following instructions set out the extent of the reduction which may be considered just and reasonable.