CG52621 - Share exchange: anti-avoidance: basic conditions

TCGA92/S137 (1) provides TCGA92/S135 will not apply unless the share exchange

• is effected for bona fide commercial reasons and
• does not form part of a scheme or arrangements of which the main purpose, or one of the main purposes, is avoidance of liability to Capital Gains Tax or Corporation Tax (this means Corporation Tax on chargeable gains).