HMRC Provides Guidance on Changes to the Capital Gains Anti-Avoidance Rule for Share Exchanges and Company Reconstructions

UK HMRC updated its Capital Gains Manual on 1 June 2026 with the publication of new guidance on the Anti-avoidance rule for share exchanges and company reconstructions from November 2025. The new guidance details changes announced in Budget 2025 (legislated in the Finance Act 2026) that went into effect on 26 November 2025, updating Section 137 of the Taxation of Chargeable Gains Act 1992 (TCGA).

Section 137 is a targeted anti-avoidance rule designed to prevent individuals or companies fro…