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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Shares acquired on same day: election for alternative treatment; share reorganisation

If certain conditions are met, the shares or securities which an individual holds after a share reorganisation, take-over or company reconstruction are treated as the same asset acquired as the shares or securities held previously were acquired. For S105A TCGA92 purposes, where shares were originally acquired on the same day the shares or securities held after a share reorganisation etc are split proportionately into two categories which respectively represent the approved-scheme shares and the other shares.