Taxes Consolidation Act 1997 section 582

Calls on shares

Section 582 deals with the capital gains tax treatment of calls on shares or debentures, ensuring that late payments towards the cost of shares are recognised as expenditure on the date the payment is actually made rather than the original allotment date.

  • Where a person pays consideration for shares or debentures more than 12 months after the allotment date, that payment is treated as expenditure incurred on the date it was actually made, not the allotment date.
  • This treatment is relevant for indexation relief purposes: the indexation multiplier under section 556 applies from the date of the call payment, not from the date the shares were originally allotted.
  • Section 582 does not apply to calls made within 12 months of allotment, so that the normal practice of paying partly on application and partly on allotment a few weeks or months later is unaffected.
  • Section 582 does not apply where the call took place before 6 April 1974, as in that case the shares are normally treated as having been acquired on that date at their market value, which already reflects the call.

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