Capital gains treatment for SPV share transfers to business trusts preserves original cost and holding period for units.

Transfer of shares of a Special Purpose Vehicle to a business trust in exchange for units allotted by the trust is treated as a transaction not regarded as a transfer for capital gains purposes. The cost of acquisition of the units in the hands of the SPV shareholder is taken as the cost at which the SPV shares were originally acquired, and the period of holding of the SPV shares is also included for any later transfer.

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