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At a practical level it may make little difference whether a subscription for new shares which is not a bargain made at arm’s length is treated as reorganisation or a purchase. If the subscription is a purchase the ordinary rules of TCGA92/S17 will apply to restrict the acquisition cost of the new shares to their market value. »Ê¹ÚÌåÓýapp adjustment to the Capital Gains Tax base cost is likely to be very similar to that achieved under TCGA92/S128. See CG53516+ if the shares are issued on the conversion of a loan account.