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Certain events and transactions which alter a holding are treated as altering the original holdings and not as disposals of the original holding.

There are special rules¹ for the calculation of the value on death in any case where, within the period of 12 months immediately following the date of the death in question, there occurs in relation to any qualifying investments (see I4.301A for the meaning of this term) comprised in the deceased's estate immediately before his death ('the original holding') any of the following events, being transactions to which TCGA 1992, s 127 applies.

1. Ìý

   (a)ÌýÌýÌýÌý any reduction in the share capital of a company

2. Ìý

   (b)ÌýÌýÌýÌý any reorganisation of the share capital of a company, including:

3. 1. Ìý

      –ÌýÌýÌýÌý any case where persons are, whether for payment or not, allotted shares in or debentures of the company in respect of and in proportion to (or as nearly as may be in proportion to) their original shareholdings, and

   2. Ìý

      –ÌýÌýÌýÌý any case where