Taxation of Chargeable Gains Act 1992 section 169SF

Application of section 169SD where sections 127 to 130 apply

Section 169SF explains how a deferred gain under the entrepreneurs' relief provisions is allocated when the shares to which the gain relates have been reorganised before the eventual disposal takes place.

• Where a share reorganisation has occurred after a gain was deferred under section 169SD, this section governs how the deferred gain is treated on any subsequent disposal of the reorganised shares.
• If only part of the new holding is disposed of, the deferred gain must be split between the shares in the new holding using the same proportions as those used to apportion the original acquisition costs under the share reorganisation rules.
• Where an individual receives consideration (such as cash) as part of the reorganisation and section 128(3) applies, the individual is treated as having made a disposal of the original shares for the purposes of the deferral provisions, potentially triggering the deferred gain at that point.
• The terms "new holding" and "original shares" carry the same meanings as in the share reorganisation rules set out in sections 126 to 130.