Corporation Tax Act 2010 section 89

Deemed time of issue for certain shares

Section 89 establishes when bonus shares are treated as having been issued for the purposes of share loss relief provisions, by deeming them to have been issued at the same time as the original shares to which they relate.

• When a company receives bonus shares that correspond to original shares it already holds, the bonus shares are treated as issued at the same time as the original shares
• This deemed timing applies for the purposes of the gross assets requirement (section 84), the unquoted status requirement (section 85), and the share substitution rules (section 88)
• The rule applies regardless of whether the original shares were actually issued to the company or were themselves treated as having been issued at a particular time under this same provision
• The practical effect is that bonus shares inherit the issue date of their corresponding original shares, ensuring that qualifying conditions are tested by reference to a single consistent date