VCM48300 - VC loss relief: special rules for share reorganisations: no new consideration given for new shares: example

ICTA88/S574 (2)(a)

The following example shows how you calculate the VC loss relief due when a qualifying trading company has made a bonus issue of shares.

  • April 1992 a taxpayer subscribes for 1,000 shares in H Ltd at a cost of £5,000.
  • April 1998 H Ltd makes a bonus issue of nine shares per each existing share held.
  • July 1999 the taxpayer sells half of the shares, at arm's length, for £3,000.
  • September 2001 H Ltd ceases trading and is placed into liquidation.
  • December 2001 the liquidator makes a final distribution of 5p per share.

The shares fall to be dealt with in a TCGA92/S104 holding. The computations are as follows:

Number of shares heldActual costIndexed cost
April 1992: Section 104 holding created
1,000

£5,000

£5,000
April 1998: indexation (factor 0.171)






£855


1,000

£5,000

£5,855
April 1998: bonus issue - 9 for 1
9,000








10,000

£5,000

£5,855
July 1999 part disposal of 5,000 shares
(5,000)

(£2,500)

(£2,928)


5,000

£2,500

£2,927
Dec 2001: disposal
(5,000)

(£2,500)

(£2,927)

Subject to any costs of disposal, the sale in July 1999 has resulted in a chargeable gain of £72 (£3,000 consideration received less indexed cost £2,928).

The distribution on winding up of the company results in an allowable loss, as follows:

Disposal proceeds(5,000 x 5 pence)
£250
less indexed cost£2,927

or actual cost£2,500[#](£2,500)
Allowable loss

£2,250

[#] For individuals, indexation has been frozen at April 1998 - see CG17207. For disposals on or after 30 November 1993 indexation allowance cannot create or enhance an allowable loss

Assuming all the conditions for relief are met, the taxpayer will be able to claim relief for the loss of £2,250 under ICTA88/S574.

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