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HMRC internal manual

Capital Gains Manual

Gifts: of Qualifying Corporate Bonds to Charities etc.

This paragraph applies if a person holds qualifying corporate bonds (QCBs) issued following a takeover or share reorganisation. In brief TCGA92/S116 (10) requires the computation of the gain that would have arisen if the shares had been sold at their market value at the date of reorganisation. This gain is deferred and accrues on a later disposal of the QCBs. See CG53723.

If the disposal is to a charity and comes within TCGA92/S257, there will no charge by reference to the deferred gain either on the donor, or on the charity on a subsequent disposal of the QCBs.