RE: How would a spin off work?22 Feb 2021 06:28
Thanks Earache, some useful info.
The base cost would be considered £nil in my opinion as it is the easiest/logical way to determine the true gain in economic benefit.
An alternative is that the dividend is recognised as income, with the income taxed accordingly, with the value of said dividend then becoming the new base cost. So, based on the previous example, £1k of dividend income, £500 of capital gain upon sale.
I do not specialise in personal tax, but i cannot see an outcome which would not result in either of the above becoming relevant. I personally think the former is the most realistic as the dividend in specie doesnt actually provide you with wealth until the share is sold. This echos the treatment of gift relief, whereby the recipient of free assets adopts them at the base cost of the previous owner, to be factored in when the recipient sells. Any eventual gain is based on the original purchase cost.
Regarding the "cost" when factoring in a proportion of an ORPH share, i dont know how this would be calculated. The ORPH price today is not based on net asset value, it is based on a combination of factors. ARB is worth £1b based on its market cap. If it were liquidated tomorrow it wouldnt end up with anything near £1b. Therefore, it's SP is based largely on sentiment/potential. Of course, someone could still consider it to be worth £1b, i'm not saying it isnt per se, but basing a business value of the balance sheet is the most basic metric and isnt used when buying/selling companies, largely due to the fact that is doesnt consider the actual company potential.
Therefore, our base cost in spin off Co wont be based on a perceived pro rate value of ORPH. At least not from what i have ever seen before. ORPH has its own base cost, the amount you bought it for, and will have it's own proceeds, the price you sell it for. Any eventual ORPH gain will be based on those two values