# Finance Act 2025, Paragraph 8: Investors’ relief: reorganisations of share capital before 30 October 2024

Extent: E+W+S+N.I.

(1) This paragraph applies for the purposes of an election under section 169VT of TCGA 1992 in relation to a reorganisation of a company where—
(a) the reorganisation takes place on or after 6 April 2023 but before 30 October 2024, and
(b) the election is made on or after 30 October 2024.
(2) If, as at 30 October 2024, a relevant individual holds qualifying shares or potentially qualifying shares, the disposal of the original shares is to be treated as taking place at the time of the election and not at the time of the reorganisation.
(3) For this purpose “a relevant individual” means—
(a) where a claim under section 169VM of TCGA 1992 is made jointly by the trustees of a settlement and an eligible beneficiary, an eligible beneficiary, and
(b) where a claim under that section is made by an individual, the individual.
(4) References in this paragraph to a reorganisation are to a reorganisation within the meaning of section 126 of TCGA 1992 or an exchange of shares or securities which is treated as such a reorganisation by virtue of section 135 or 136 of that Act, applying for the purposes of this paragraph the provision made by sections 169VN to 169VS of that Act.
(5) In this paragraph “qualifying shares” and “potentially qualifying shares” have the meaning given by section 169VB of that Act.

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Source: https://www.legislation.gov.uk/ukpga/2025/8/schedule/2/paragraph/8 (the official version)
Page: https://openlegislation.uk/finance-act-2025/schedule-2/paragraph-8
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.