Share for share exchange CGT relief (Tax newsletter, July 2010)

The case of Peter Hadfield -v- HMRC [2010] UKFTT 261 serves as a reminder of the strict terms of share for share exchange CGT relief. Under s.135 TCGA 1992, where one company issues shares or debentures in exchange for shares or debentures of another company then this will be treated as not giving rise to a disposal provided certain other conditions are satisfied which are not relevant to the issue contested in this case.

Mr Hadfield had accepted an "exchange offer" by Royal Dutch Shell (RDS) of two "A Shares" for every share in Royal Dutch Petroleum Company (RD). The consideration for the share exchange was satisfied by a declaration of trust over "A Shares" in RDS by a newly created SPV company. The tribunal concluded that this was not an issue of shares within the meaning of the requirement in s.135 TCGA 1992.

This case serves as a reminder that the strict technical requirements of s.135 TCGA 1992 need to be met to qualify for share for share exchange relief on a share exchange. Particular care needs to be taken to ensure these rules are fully satisfied in transactions involving management shareholders exchanging shareholdings in a target company for shareholdings in the new top holding company of the group. A direct issue of shares by the top holding company cannot qualify for this relief if the acquiring company is a subsidiary of the top holding company. Often these transactions are structured so that the share exchange takes place in a "roll-up transaction" by way of a sequence of steps, but such arrangements need to be structured to ensure the management shareholders acquire beneficial ownership of the shares issued at each step.

 

Please click on the links below for the other articles in the July 2010 tax newsletter.

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This newsletter is not intended to be a comprehensive review of all developments in the law and practice, or to cover all aspects of those referred to. Readers should take legal advice before applying the information contained in this publication to specific issues or transactions.