Corporation Tax Act 2010

Stock dividends

108 (1) This paragraph applies if—

(a) share capital is issued by a UK resident company in respect of shares in the company issued before 6 April 1975 (“the old shares”),

(b) the old shares confer on the holder a right to convert them into, or exchange them for, shares of a different class, and

(c) the case falls within section 410(2), (3) or (4) of ITTOIA 2005 (whether or not that section in fact applies).

(2) Section 1049 (stock dividends) does not apply to the protected part of any bonus share capital issued by the company after 5 April 1976 in connection with an exercise of the right mentioned in sub-paragraph (1)(b).

(3) For the purposes of sub-paragraph (2), the protected part of the bonus share capital is however much of it (if any) would have been issued if the right had been exercised so as to bring about the conversion or exchange of the shares on the earliest possible date after 5 April 1975.