Changes in shareholdings: changes in the capitalisation of a company
Special rules apply when there is a change to the shareholdings that are being dealt with by the ‘appropriate person’ (IHTM34161) as a result of changes in the capitalisation of a company.
IHTA84/S183 applies when
- within a year of death
- in relation to any of the ‘qualifying investments’ (IHTM34131)
there is a transaction to which TCGA92/S127applies.Broadly speaking this means a transaction involving a
- a reorganisation of capital
- a conversion of securities
- an issue of shares or debentures (in certain circumstances)
- changes to a unit trust scheme that corresponds to any of the above transactions.A transaction within IHTA84/S183 is not treated as a sale. For the purposes of the relief the new holding which results from the transaction is treated as being the same as the original holding.