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HMRC internal manual

Capital Gains Manual

Company reconstructions: shareholder: TCGA92/S136 disapplied: tax unpaid


The guidance at CG52670 applies if

  • TCGA92/S137 has prevented TCGA92/S136 from applying and
  • the tax on the disposal is unpaid for six months and
  • the new shares or debentures have been transferred to a husband or wife or civil partner of the transferee or to a member of the same group of companies.