75.    Distributions in specie by company

 

(1)       Where a company makes a distribution of an asset in specie to a person holding a share in that company-

 

(a)     that company must be treated as having disposed of that asset to that person on the date of distribution for an amount received or accrued equal to the market value of that asset on that date; and

(b)     that person must be treated as having acquired that asset on the date of distribution and for expenditure equal to the market value of that asset on that date, which expenditure must be treated as an amount of expenditure actually incurred for the purposes of paragraph 20(1)(a).