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HMRC internal manual

Capital Gains Manual

Reorganisations of share capital: partly-paid shares issued

You can treat partly-paid shares issued in a rights issue as being of the same class as the original fully paid shares if the subscription price is payable in full within six months, see CG50207. This could affect the possible operation of TCGA92/S130. You must use the strict statutory method of computation by treating the partly-paid shares and the fully paid-up shares as being in two separate section 104 pools if this is to the customer’s advantage.