C1Part 4Loss relief
Chapter 5Losses on disposal of shares
Qualifying trading companies: supplementary
88Substitution of new shares for old shares
1
Subsection (2) applies if, in the case of any new shares held by a company or by a nominee for a company, the old shares for which they were exchanged were shares which had been subscribed for by the company (“the investor”).
2
This Chapter has effect in relation to any subsequent disposal or other event as if—
a
the new shares had been subscribed for by the investor at the time when, and for the amount for which, the old shares were subscribed for by the investor,
b
the new shares had been issued by the new company at the time when the old shares were issued to the investor by the old company, and
c
any requirements of this Chapter which were met at any time before the exchange by the old company had been met at that time by the new company.
3
Nothing in subsection (2) applies in relation to section 195(7) of ITA 2007 as applied by section 79(7) above for the purpose of the definition of “excluded activities”.
Pt. 4 modified (with effect in accordance with reg. 1(2) of the amending S.I.) by The Risk Transformation (Tax) Regulations 2017 (S.I. 2017/1271), regs. 1(1), 10