Taxation of Chargeable Gains Act 1992 Schedule 5AA paragraph 8

Interpretation

Section 8 of Schedule 5AA defines key terms used throughout the Schedule, specifically "ordinary share capital" and "reorganisation of share capital".

  • "Ordinary share capital" takes the standard Corporation Tax Act 2010 definition — all issued share capital other than capital carrying only a fixed-rate dividend entitlement
  • For unit trust schemes, rights treated as shares under the TCGA 1992 rules for unit trusts count as ordinary share capital
  • For companies without share capital, any membership interests held by members are treated as ordinary share capital
  • References to a reorganisation of share capital mean a reorganisation as defined for capital gains purposes under TCGA 1992 section 126

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