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HMRC have published Revenue & Customs Brief 16/09 relating to the consequences of the transfer of Bradford & Bingley plc into public ownership in relation to the capital gains tax position of former shareholders and the income tax and capital gains tax position of those who held shares and share options under employee share schemes.
The Revenue considers that the entire loss to the shareholder of his or her shares under the Transfer Order is an occasion of disposal under TCGA 1992 s 24(1).
The time of the disposal will be 29 September 2008 the date the Transfer Order came into force.
As no consideration was received for the shares the disposal on that date will normally give rise to a loss in respect of any allowable costs of acquisition.
Where the disposal includes free shares received by the same holder when Bradford & Bingley demutualised...
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