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HMRC internal manual

Capital Gains Manual

Substantial shareholdings exemption: interaction with other legislation - appropriation of asset to trading stock


Paragraph 36 Schedule 7AC TCGA 1992 applies where a company appropriates shares to trading stock. It ensures that the company is still treated as having acquired the shares at market value for the purposes of its trade even when no chargeable gain or allowable loss, as referred to in section 161(1) TCGA 1992, arises because of the substantial shareholdings exemption regime.