Income Tax Act 2007 section 150

Deemed time of issue for certain shares

Section 150 establishes the rules for determining when shares are treated as having been issued for the purposes of certain qualifying conditions, specifically when shares have been transferred between spouses or civil partners, or when bonus shares have been issued.

• The section applies to the gross assets requirement (section 142), the unquoted status requirement (section 143), and the substitution of new shares for old shares (section 146).
• Where shares are transferred between spouses or civil partners during their lifetimes, the shares are treated as having been issued to the recipient at the same time they were originally issued to the transferor.
• Bonus shares issued in respect of existing shares are treated as having been issued at the same time as the original shares to which they relate.
• These deemed issue date rules can apply in combination — for example, where bonus shares are issued on shares that were themselves received via a spousal transfer.