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thefierce1:

I might be beg to differ with "Remember FOLLOW THE MONEY...why would bigMJ, I believe the 3rd largest individual shareholder continue buying 100”s of 00000”s of shares"

check the MTR website... According to the update on 1st October bigMJ's holding was 4.83% (65,238,511). Shares in Issue 1,349,956,065.

So for MJ to cross 5% he needs to reach 67,497,804 an increase of the 'declared' holding of 2,259,293 shares - right?

Recently he stated he bought £50K, which I do not doubt. You work out whether the £50K would have bought more than the 2,259,293 shares to trigger a 5% TR1 (The SP was around 1.3/1.2p)

In my mind, if some of his 'declared' holding had not been partially sold down the 5% threshold should have been crossed already.....

You can work it all out for yourself..

Perhaps one of the 'HNW' that Bonker was alluding to as taking the SP right down to it's current level....

Putting out for discussion here after contacting HMRC...

I've been in contact with HMRC regarding another unrelated share that I had which was AIM delisted and thus moved from ISA to Taxable account.

The question I posed to HMRC was: which 'purchase' price should I be taking in relation to a share moved to a Taxable account. Should it be:

(1) The last trading mid-price of the share prior to suspension/delisting or
(2) The original share purchase price within the ISA

The HMRC view is that it is the latter of the two, i.e. the original share purchase price that should be considered when calculating a taxable gain or loss within a taxable account.

I argued against that as the "price per share" entering the taxable account/status is the last mid-price prior to delisting (moving from ISA status to taxable status)

That argument was rejected by HMRC as their view is that within the ISA you may have a 'paper' gain or 'paper' loss which has not been crystallised [this is the critical point] as no sale has taken place, thus they have to take the original purchase price into consideration when calculating a taxable gain or loss.

So it seems the situation for LION holders is even more complex now..

For 'traders' or multi-purchases of LION within an ISA the taxpayer will have to create a 'section 104' holding in order to calculate the 'new starting position' when LION moves to their taxable account.

Some may benefit if their overall share purchase average price is above 2.65p and when relisting occurs at say 2.65p they will have a 'paper' taxable loss starting position.

However, if holders have purchased/traded LION at much much lower, let's say average price 1p or below (calculated by section 104 holding) then when listing occurs at say 2.65p they will have an immediate 'paper' taxable gain starting position. This will not bode well for those that wish to bed & ISA upon relisting as the taxable gain may be much larger than expected.

I hope all that makes sense. It might be worthwhile some others contacting HMRC to see if there is a consensus on their position regarding CGT.

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