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HMRC internal manual

Capital Gains Manual

Value shifting: time of disposal

The disposal takes place when the value actually passes. Sometimes, the transfer of value may occur as soon as control is exercised. In other cases there may be an interval between the time when control is exercised, and when the value actually passes. For example, the controlling shareholders may approve an increase in a company’s authorised share capital to enable a further issue of shares, but the actual issue may take place some while later.

So long as the increase in share capital is a part of the arrangements designed to result in the transfer of value, then the value shifting rules will apply, at whatever date the shares are subsequently issued.