I don't think the tax department are going to be sympathetic to your cause. They will see this as a black and white transaction and you will only get CGT relief on the shares actually rolled over. As far as they are concerned the rollover only means you have just deferred your CGT payment until you dispose of your Tullow shares. If the cash component was CGT free then they would never recoup the tax which makes it inconsistent with the whole rollover policy.
The question I have is if you have different lots of shares purchased at different prices, then presumably you can choose which ones are being rolled over and which ones are being sold as you would with a normal disposal? Any comments
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