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HMRC internal manual

Capital Gains Manual

Reorganisations of share capital: apportionment of cost under section 130: listings at different times

TCGA92/S130(1) gives a three month period in which the shares or debentures must achieve a listing. This gives the company time to arrange a listing for new shares or debentures. In the meantime the original shares may continue to be listed. It would defeat the object of Section 130 if the new shares were treated as not listed (so that TCGA92/S129 applied) immediately after the rights issue but they were then listed within the three month time limit (so that section 130 applied). This would impose an unnecessary valuation burden on HMRC and customer alike. Therefore, if the new holding consists of more than one class of listed share or listed debenture, you make the apportionment on the first day, in the three month period, in which all such securities are in fact listed.