CG51981 - Reorganisations of share capital: creation of separate holdings: example using section 130
This example illustrates the operation of TCGA92/S130 if the original shares are in a Section 104 holding.
- May 2022: a taxpayer buys 8,000 25p Ordinary shares in L PLC at a price of 160p per share. Total cost £12,800.
- December 2023: L PLC makes a 5:8 rights issue of 50p Convertible Redeemable Preference shares at 100p per share payable on 3 January 2024. Total shares acquired 5,000. Total cost £5,000.
The market value of the two classes of share on 13 December 2023, the first day prices are quoted for the shares in the new holding, is
25p Ordinary shares |
135p |
50p Convertible Redeemable Pref. shares |
100.25p per share (100p plus a premium of |
0.25p per share) |
These values are used to apportion the total cost of the new holding (£12,800 + £5,000 = £17,800) between the two different classes of share:
The pool of 8,000 25p Ordinary shares
The total cost attributed to the pooled Ordinary shares is
£17,800 x [market value of 8,000 25p Ordinary shares / (market value of 8,000 25p Ordinary shares plus market value of 5,000 50p Preference shares)] ie
£17,800 x (8,000 x £1.35) / [(8,000 x £1.35) + (5,000 x £1.0025)] = £12,157
The pool of 5,000 50p Preference shares
The total cost attributed to the pooled Preference shares is
£17,800 x [market value of 5,000 50p Preference shares / (market value of 8,000 25p Ordinary shares plus market value of 5,000 50p Preference shares)] ie
£17,800 x (5,000 x £1.0025) / [(8,000 x £1.35) + (5,000 x £1.0025)] = £5,643