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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: creation of separate holdings

Once the apportionment has been made, each holding of a different class of share or debenture is treated as though it had been acquired separately at the same date as the original shares from which it was derived. If the original shares were held in a Section 104 holding, see CG51730, each different class of share or debenture will be held in a separate Section 104 holding.

Where a gain is charged to corporation tax (rather than to capital gains tax) and the original shares were held at 6 April 1965, rules apply to exclude from charge any gain attributable to the period before that date, see CG51641.