CG52767 - Company reconstructions: shareholder: TCGA92/S136 disapplied: tax unpaid

TCGA92/S136

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 spouse or civil partner of the transferee or to a member of the same group of companies.