results in a new holding being equated with the original holding for the purposes of capital gains tax, or

would have that result but for the fact that what would be the new holding consists of or includes a qualifying corporate bond.

that issue of shares does not by itself count as a transaction within sub-paragraph (2); and

if made as part of a transaction within that sub-paragraph (that is, as part of a company reconstruction), the shares issued are to be regarded as not forming part of the new holding.

redeemable shares or securities issued as mentioned in F1paragraph C or D in section 1000(1) of CTA 2010 (distributions);

share capital issued in circumstances such that F2section 1022(3) of CTA 2010 (bonus issues) applies;

share capital to which F3section 410 of ITTOIA 2005 (stock dividends) applies that is issued in a case where subsection (2) or (3) of that section applies.

as referring to the new shares, or

as including those shares,

a company reconstruction is to be treated as not involving a disposal of the shares comprised in the original holding;

new shares are to be treated as having been awarded to the participant on the date on which the corresponding old shares were awarded;

the conditions in Part 4 of this Schedule (types of share that may be awarded) are to be treated as fulfilled with respect to any new shares if they were (or were treated as) fulfilled with respect to the corresponding old shares; and

“new shares” means shares comprised in the new holding which were issued in respect of, or otherwise represent, shares comprised in the original holding;

“the new holding” and “the original holding” mean respectively the new and original holdings mentioned in paragraph 86(2);

“corresponding old shares”, in relation to any new shares, means the shares in respect of which the new shares are issued or which the new shares otherwise represent.

identical to the shares in respect of which the rights were conferred, and

appropriated to, or acquired on behalf of, the participant under the plan in the same way and at the same time as those shares.

that the funds used by the trustees to exercise the rights are not provided by the exercise of the trustees' powers under paragraph 77 (trustees' powers to raise funds to subscribe for rights issue);

that similar rights are not conferred in respect of all ordinary shares in the company.

any shares, securities or rights allotted are not plan shares, and

sections 127 to 130 of TCGA 1992 (reorganisation of share capital etc.) do not apply in relation to them.

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

the trustees,

each individual who has plan shares, and

each individual who has entered into a partnership share agreement which was in force immediately before the notice was issued.

the end of the notice period, or

the first date on which the shares may be removed from the plan without giving rise to a charge to income tax under sections 501 to 507 (SIPs: tax charges) on the participant on whose behalf they are held.

transferring the shares to the participant on behalf of whom they are held, or to another person, at the participant’s direction, or

disposing of the shares and accounting (or holding themselves ready to account) for the proceeds to the participant or to another person at the participant’s direction.

the jointly owned company, and

any company controlled by that company.

a constituent company in more than one group plan, or

a constituent company in a particular group plan if another company within that sub-paragraph is a constituent company in a different group plan.

of which 50% of the issued share capital is owned by one person and 50% by another, and

which is not controlled by any one person.

to a date or dates, or

to an average of the values on a number of dates,

which the officer reasonably requires for the performance of any functions of Her Majesty's Revenue and Customs or an officer of Revenue and Customs under the SIP code, and

which the person to whom the notice is addressed has or can reasonably obtain.

information about the administration of a plan and any proposed alteration of the terms of a plan.

one has control of the other, or

both are under the control of the same person or persons.

they are transferred by the trustees to the participant, or another person, on the direction of the participant,

the participant assigns, charges or otherwise disposes of the beneficial interest in the shares, or

they are disposed of by the trustees, on the direction of the participant, in circumstances where the trustees account (or hold themselves ready to account) for the proceeds to the participant or to another person.

they are withdrawn from the plan,

the participant to whom the shares were awarded ceases to be in relevant employment at a time when the shares are subject to the plan, or

the trustees dispose of the shares under provision made in accordance with paragraph 79 (meeting by trustees of PAYE obligations).

participates in an award of partnership shares, and

ceases to be in relevant employment at any time during the acquisition period relating to that award,

where there was no accumulation period, the period beginning with the deduction of the partnership share money and ending with the acquisition date (as defined by paragraph 50(4)), and

where there was an accumulation period, the period beginning with the end of that period and ending immediately before the acquisition date (as defined by paragraph 52(5)).

which between them beneficially own not less than 75% of the other company’s ordinary share capital, and

each of which beneficially owns not less than 5% of that capital.

shares are subject to a “restriction” if there is any contract, agreement, arrangement or condition which makes provision to which any of subsections (2) to (4) of section 423 (restricted securities) would apply if the references in those subsections to the employment-related securities were to the shares, and

the “restriction” is that provision.