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Income Tax (Earnings and Pensions) Act 2003

Paragraph 86: Company reconstructions

3203.This paragraph deals with company reconstructions, and is the first of two that derive from paragraph 115 of Schedule 8. This paragraph derives from sub-paragraphs (1) and (2) of paragraph 115, and deals with the meaning of the expression “company reconstruction”. The consequences of company reconstructions are dealt with in paragraph 87 of this Schedule.

3204.Sub-paragraph (3)(a) is new; and specifies the consequences of the making of what is now termed an “excluded issue of shares”. This material is not contained in the source legislation; but the new material is merely declaratory of the law in order to make those consequences explicit. See Note 67 in Annex 2.

3205.In sub-paragraph (4), the label “excluded issue of shares” is new.

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