Beta This part of GOV.UK is being rebuilt – find out what this means

HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
, see all updates

Share reorganisations: consideration paid: anti- avoidance

If a taxpayer acquires an asset otherwise than by way of a bargain made at arm’s length the Capital Gains Tax base cost will be established by TCGA92/S17. The market value of the asset will be substituted for the consideration paid to acquire the asset, see CG14530+. However, Section 17 cannot apply to a reorganisation because it is treated as not involving any acquisition of the shares. In the case of Dunstan v Young, Austen & Young Ltd the company was allowed its deduction.