D6.206 Share For Share Exchange—Qualifying Circumstances

Home / Simons-Taxes /Corporate tax /Part D6 Company reconstruction and profit extraction /Division D6.2 Reorganisation of share capital /Exchange of securities / D6.206 Share for share exchange—qualifying circumstances

Commentary

Corporate tax

The share exchange rules apply where one company ('company B') acquires shares in, or debentures of, another company ('company A') and in exchange issues its own shares or debentures¹. The three sets of circumstances where the provisions apply are as follows²:

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•�� Where company B acquires as a result of the exchange, or already holds, over one-quarter of the ordinary share capital of company

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