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A sole shareholder receives new shares through a capital increase funded by reserves. The DGT rules that the issuance of these fully paid-up shares does not constitute income; however, their acquisition value for future sales is determined by dividing the cost of the original shares by the total number of shares.
This ruling clarifies the tax basis for shares acquired through capitalisation of reserves, ensuring that the cost of original holdings is spread across the new total number of shares to prevent artificial capital gains.
The tax team reviews your specific situation.
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