Income Tax Act 2007 (c. 3)

Part 4 U.K. Loss relief

Chapter 6 U.K. Losses on disposal of shares

Miscellaneous and supplementary U.K.

150 Deemed time of issue for certain shares U.K.

(1) In this section “the relevant provisions” means—

• section 134(5)(a),

• section 142(1)(a) and (2)(a),

• section 143(1), and

• section 146(2)(b).

(2) If—

(a) any shares were issued to an individual (“A”) or are treated under subsection (3) or this subsection as having been issued to A at a particular time,

(b) the shares are transferred by A to another individual (“B”) during their lives, and

(c) A was B's spouse or civil partner at the time of the transfer,

the shares are treated for the purposes of the relevant provisions as having been issued to B at the time they were issued to A or are treated as having been so issued.

(3) If—

(a) any shares (“the original shares”) have been issued to an individual, or are treated under subsection (2) or this subsection as having been issued to an individual at a particular time, and

(b) any corresponding bonus shares are subsequently issued to the individual,

the bonus shares are treated for the purposes of the relevant provisions as having been issued at the time the original shares were issued to the individual or are treated as having been so issued.