CG50242 - Definitions: tax analysis

If a person `converts' shares into DR form, there is no change in their ownership of the underlying shares, but they have acquired a second asset, the DR itself. If a person `converts` their DR back into the underlying shares, there is again no change in their ownership of the shares, but there will have been a disposal of the separate DR asset. Normal TCGA principles would apply to this disposal. Normally there will be no chargeable gain on such an event.