Taxation of Chargeable Gains Act 1992 section 169VP

Reorganisations where consideration given

Section 169VP sets out how shares are treated for investors' relief purposes when a share reorganisation takes place and the shareholder pays (or becomes liable to pay) consideration for some or all of the new shares received.

• Where a qualifying person holds ordinary shares before a reorganisation and pays consideration for new shares issued to them, those shares are treated as having been issued on their actual date of issue, not the date the original shares were issued.
• If the new holding includes both shares issued for consideration and shares issued without consideration, the two parts are treated separately for the purpose of determining their investors' relief status.
• For any part of the new holding where no consideration was given, the rules that apply to reorganisations without consideration (from sections 169VN and 169VO) are used, but applied only to that specific part of the holding.
• The "status" of each share — whether it is qualifying, potentially qualifying, or excluded for investors' relief — is assessed according to these rules when a subsequent disposal of the new holding (or part of it) takes place.