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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Share exchange: TCGA92/S135: 1982 holding

If the original shares were held in a 1982 holding, see CG50870+, the new shares or debentures will also be held in a 1982 holding. For rebasing and indexation purposes the valuation you need is of the shares the taxpayer actually held on 31 March 1982. Any later takeover will not affect this valuation.

Quoted shares

If the original shares were quoted on 31 March 1982 you can use Extel to establish their 31 March 1982 value. You may also be able to use the Extel adjustment factors to check taxpayers’ computations, see CG52050.

Unquoted shares

If the shares were unquoted on 31 March 1982 you must refer the valuation to Shares and Assets Valuation even if the later takeover is by a quoted company. The valuation you need is of all the shares held on 31 March 1982 and not merely the shares sold.


  • A taxpayer has a 1982 holding of 10,000 £1 ordinary shares in Searchers Ltd.
  • November 1986 Searchers Ltd is taken over by Trendsetters Ltd, a quoted company. Trendsetters Ltd issues three of its own shares for each Searchers Ltd share held.
  • November 1994 the taxpayer sells 20,000 of the holding of 30,000 shares in Trendsetters Ltd.

The valuation you need is of 10,000 shares in Searchers Ltd. Assuming it existed in March 1982 Trendsetters Ltd was an entirely different company to Searchers Ltd. There is no reason why a valuation of 10,000 shares in Trendsetters Ltd as at 31 March 1982 should bear any relation to the value of a holding of 10,000 shares in Searchers Ltd.