UK: Guidance on amended anti-avoidance rule for share exchanges and company reconstruction
Rule was amended in Finance Act 2026 effective for transactions from November 26, 2025.
HMRC published guidance on the anti‑avoidance rule for share exchanges and company reconstructions, which was amended in Finance Act 2026 effective for transactions from November 26, 2025, in the form of Appendix 20 to the capital gains tax (CGT) manual (CG‑APP20).
The amendments were intended to address weaknesses in the previous version of the rule that were highlighted by the Court of Appeal in Delinian Ltd v. HMRC [2023] EWCA Civ 1281 (often referred to as the “Euromoney” case).
CG-APP20 replaces most of the earlier provisional guidance set out in Appendix 19 (CG-APP19), which remains relevant only for transitional cases.
Read a June 2026 report prepared by the KPMG member firm in the UK