Reorganisation of share capital, conversion of securities, etc.
27(1)For the purposes of this Part of this Act, including Part I of this Schedule, it shall be assumed that any shares or securities held by a person on 6th April 1965 (identified in accordance with the last foregoing paragraph) which, in accordance with paragraph 4 of Schedule 7 to this Act as extended by paragraphs 5 and 6 of that Schedule, are to be regarded as being or forming part of a new holding were sold and immediately re-acquired by him on 6th April 1965 at their market value on that date.
(2)If, at any time after 5th April 1965, a person comes to have, in accordance with the said paragraph 4 as so extended, a new holding sub-paragraphs (3) to (5) of paragraph 24 of this Schedule shall have effect as if—
(a)the new holding had at that time been sold by the owner, and immediately reacquired by him, at its market value at that time, and
(b)accordingly, the amount of any gain on a disposal of the new holding or any part of it shall be computed—
(i)by apportioning in accordance with the said paragraph 24 the gain or loss over a period ending at the said time, and
(ii)by bringing into account the entire gain or loss over the period from that time to the date of the disposal.
(3)This paragraph shall not apply in relation to a reorganisation of a company's share capital if the new holding differs only from the original shares in being a different number, whether greater or less, of shares of the same class as the original shares.