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BR Pub 19/05 - BR Pub 19/06
05 Dec 2019
These rulings will apply for an indefinite period beginning on 1 April 2020

Income tax - treatment of alteration to rights attached to shares under section CB 4; Income tax - treatment of a disposal of shares with altered rights under section CB 4

The rulings concern an arrangement where a shareholder holds shares in a company and the shares were acquired for the purpose of disposal. Subsequently, the rights attached to the shares are altered and the following applies: The shares are in a company registered under the Companies Act 1993; the alteration is not structured as a cancellation and issue of shares. To avoid doubt, the rulings do not include an arrangement where s BG 1 applies to void the arrangement. The rulings conclude that an alteration of share rights does not result in a disposal of personal property for the purposes of s CB 4, and the time of acquisition of the shares where the rights attached to them are altered after acquisition is the time the shares were acquired before the alteration.


BR Pub 19/05

BR Pub 19/06

TIB Volume 32 No 1 February 2020