Two Tier Rollovers

The 'no disposal' fiction in section 127 Taxation of Chargeable Gains Act 1992 is applied by virtue of section 135 on share for share exchanges. The basic conditions are that a company (company A) issues shares or debentures to a person in exchange for shares in or debentures of another company (company B). The Inland Revenue Capital Gains Tax Manual says at paragraph CG52521:

'In effect company A is buying shares or debentures in company B but paying for all or part of the purchase by issuing its own shares or debentures. The purchase can include any combination of shares and debentures. Therefore shares can be issued for shares and debentures. Debentures can be issued for debentures and shares.'

Leaving aside the more detailed qualifying conditions it is clear not only from the face of the legislation but...