Apportionments on demerger

[Alaric]

It is my understanding that when a Company splits into two, a demerger in other words, the UK tax consequence is that the original purchase price is apportioned between the two. That's provided the event is NOT treated as a dividend distribution, so it's only the eventual CGT liability that's relevant.

It's also my understanding that there's a factor agreed with HMRC for the apportionment .

Although important to private investors, such factors can be elusive to find, either by Google search or from corporate websites.

A case in point is Investec.

This spun off Nonety One plc in 2020 and has just completed a further distribution of Ninety One shares The first distribution was not treated as a dividend as witnessed by its non-appearance in the Broker's tax statement for the 2019-20 yaer. Perhaps they haven't established the treatment of the second one, but in any event, can the factor(s) be found anywhere?

[Dod101]

Presumably the same consideration will apply with the Glaxo demerger coming up in July, although as my Glaxo (sorry GSK) shares are currently all held in an ISA it will not matter to me.

Dod