Legislation – Finance Act 2025
Schedule 2Sections 7 to 10 : transitional provision
Part 3Anti-forestalling provisions: sections 8(3) and (6) and 9(4) and (8)
Investors’ relief: reorganisations of share capital on or after 30 October 2024 but before 6 April 2026
20
(1)
This paragraph applies for the purposes of an election under section 169VT of TCGA 1992 in relation to a reorganisation of a company where—
(a)
the reorganisation takes place on or after 30 October 2024 but before 6 April 2026, and
(b)
the election is made on or after 30 October 2024.
(2)
If, when the election is made, a relevant individual holds qualifying shares or potentially qualifying shares, the disposal of the original shares is to be treated as taking place at the time of the election and not at the time of the reorganisation.
(3)
If, at any time (“the relevant time”) before the making of the election, a relevant individual ceases to hold qualifying shares or potentially qualifying shares, the disposal of the original shares is to be treated as taking place immediately before the relevant time and not at the time of the reorganisation.
(4)
For the purposes of this paragraph “a relevant individual” means—
(a)
where a claim under section 169VM of TCGA 1992 is made jointly by the trustees of a settlement and an eligible beneficiary, an eligible beneficiary, and
(b)
where a claim under that section is made by an individual, the individual.
(5)
References in this paragraph to a reorganisation are to a reorganisation within the meaning of section 126 of TCGA 1992 or an exchange of shares or securities which is treated as such a reorganisation by virtue of section 135 or 136 of that Act, applying for the purposes of this paragraph the provision made by sections 169VN to 169VS of that Act.
(6)
In this paragraph “qualifying shares” and “potentially qualifying shares” have the meaning given by section 169VB of that Act.
(7)
This paragraph does not apply if both the reorganisation and the election occur in the same tax year.