If the consideration for the new holding is only partly shares or debentures, with the other part being, for example, cash, a corresponding proportion of the original shares or debentures will be treated as disposed of for the cash1, with the cash received being treated as a capital distribution in respect of the original shares2.
A capital distribution constitutes a part disposal, unless the amount received is 'small' (see below).
Consequently, the normal part disposal rules3 apply (see Division C2.4), meaning that the cost of acquisition of the part disposal is:
where:
- Ìý
ÌýÌýÌýÌý A is the consideration received
- Ìý
ÌýÌýÌýÌý B is the value of the new holding after the disposal, and
- Ìý
ÌýÌýÌýÌý C is the allowable cost of the original holding
Example 1
H purchased 12,000 shares in J plc in May 2013 for £24,000. In 2018, L plc makes a takeover bid for J plc, offering 3 of its own shares for every 2 shares in J plc,
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