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HMRC internal manual

Capital Gains Manual

Company reconstructions: shareholder: effect of TCGA92/S136

The effect of TCGA92/S136 is to treat the companies involved as if they were the same company and to treat the new shares and debentures as though they were issued in exchange for the original shares or debentures. (If those original shares and debentures are retained they are treated as if they had been cancelled and replaced by a new issue.) In effect a scheme of reconstruction is treated as though it was a share reorganisation. TCGA92/126 - TCGA92/131 applies with any necessary modifications.

If the taxpayer still holds the original shares or debentures these are treated as though they were cancelled and reissued.