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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Reorganisations of share capital: apportioning costs: listed shares and units in unit trusts

Where a new holding consists of more than one class of share or debenture and one or more of those classes is listed on a recognised stock exchange in the UK or elsewhere within three months of the reorganisation (or within such longer time as the Board may allow), TCGA92/S130 applies to the apportionment of cost of a new holding in place of the rule in TCGA92/S129.

TCGA92/S130 applies to units of investment in unit trust schemes as it applies to shares and debentures in companies. So if a new holding includes more than one class of unit and the price of one or more of those classes of unit is published daily by the managers of the scheme at any time within three months of the reorganisation (or within such longer time as the Board may allow) then the apportionment rule in section 130 applies rather than the rule in section 129. Any claim to take advantage of the Board’s discretion to extend the three month time limit should be referred to Specialist PT (CG Technical) at Solihull.

The guidance on the effects of TCGA92/S130 is in two parts.

  • CG51976 - CG51982 are a practical guide to the operation of the section. These should enable you to deal with most of the questions which arise on the day-to-day operation of the section.
  • CG51995 - CG52002 look at the statutory background in more detail. This guidance is most likely to be of interest to Officers responsible for quoted companies who have been asked for guidance on the operation of the section.