Taxation of Chargeable Gains Act 1992 Schedule 7AC paragraph 11

Effect of deemed disposal and reacquisition

Section 11 deals with how a deemed disposal and reacquisition of shares breaks the continuous holding period required for the substantial shareholding exemption.

• A deemed disposal and reacquisition breaks the continuous holding period for shares or interests in shares
• This applies whether the deemed event affects the shares themselves or shares from which they are derived
• A deemed disposal and reacquisition is one treated as occurring under any corporation tax enactment
• This contrasts with no gain/no loss transfers, which extend the holding period rather than breaking it