Income Tax Act 2007 section 39

Disposals of new shares

Section 39 of Schedule 2 provides a transitional rule for the disposal of "new shares" that were issued before 6 April 2007, modifying how the general disposal rule in section 136(2) applies to those shares.

• This paragraph applies only to new shares issued before 6 April 2007
• Section 136(2), which deals with disposals of shares, applies to these pre-April 2007 new shares but without the restriction that makes it subject to section 145(3)
• The effect is that for these older new shares, the share exchange rules in section 145(3) do not override the general disposal treatment
• The term "new shares" takes its meaning from section 145, which deals with relief after an exchange of shares for shares in another company