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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Share reorganisations: consideration paid: general

As a reorganisation is treated as not involving the acquisition of any new shares aspecial rule is required for dealing with any consideration actually paid for the new holding. TCGA92/S128 (1) provides any consideration which is given for the new holding is deemed to have been incurred on the original shares. This is most relevant to rights issues.