Income Tax Act 2007 Schedule 2 paragraph 49

Substitution of new shares for old shares

Paragraph 49 of Schedule 2 restricts the application of the share substitution rule in Section 146 by excluding shares issued before a specified date.

• Section 146 deals with the substitution of new shares for old shares in the context of loss relief on disposal of shares
• The share substitution rule in Section 146 does not apply to shares issued before 6 April 1998
• This transitional provision ensures that pre-1998 share issues are not caught by the substitution rules
• The restriction forms part of the transitional and saving provisions in Schedule 2 of the Income Tax Act 2007