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.