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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Conversion of securities: general

TCGA92/S132 provides that the share reorganisation provisions of TCGA92/S127 to TCGA92/S131 apply, with any necessary adaptations, to the conversion of securities as they apply to a share reorganisation. The main adaptation is to substitute `security’ for the reference to `share’. No adaptations are required to the computational regime. Therefore, a conversion of securities is treated as not involving any disposal of the original securities or acquisition of the new holding of securities. Instead the original securities and the new holding are regarded as the same asset acquired as the original securities were acquired.