ANNEX 1:: MINOR CHANGES IN THE LAW MADE BY THE BILL This change is in the taxpayer’s favour in principle. But it is expected to have no practical effect as it is in line with current practice.
Change 21: Share loss relief: transfer of shares between spouses or civil partners: effect of earlier application of section 135(3) or (4): section 135
This change introduces into section 135(3)(a) a reference to A being treated under section 135(3) or (4) as having subscribed for the shares, in order to deal explicitly with cases of the issue of corresponding bonus shares and sequential transfers of shares between spouses or civil partners.
The cases in question are those involving:
	corresponding bonus shares which are treated under section 135(4) as having been subscribed for by A in consideration of money or money’s worth (see Change 23); and
	shares which have been subscribed for by an individual in consideration of money or money’s worth and which are treated as subscribed for by A as a result of the operation of section 135(3) on a previous transfer to A by that individual at a time when that individual was A’s spouse or civil partner (whether that individual is B or another).