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Definition of pre-change assets

A pre-change asset means an asset held by the relevant company before the relevant time¹, the relevant time being the date upon which there is a qualifying change of ownership²).

There are specific rules to ensure the continuity of identification of a pre-change asset where gains and losses on such assets are deferred or rolled over by virtue of the application of various other provisions in TCGA 1992. This includes:

1. Ìý

   •ÌýÌýÌýÌý a new asset whose value derives in whole or in part from a pre-change asset and is held by any company (A) at or after a change of ownership, unless it was acquired by A under a transaction other than an intra-group transaction³. The value of an asset may derive from another asset where assets have been merged, divided or have changed their nature or rights or interests in assets have been created or extinguished⁴

2. Ìý

   •ÌýÌýÌýÌý a pre-change asset that was a holding of shares or securities (the 'old asset'). On a reorganisation, conversion