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Euromoney plc sold some shares for $85m in a commercial transaction. It originally intended to take $21m in cash and the rest in ordinary shares, but at a fairly late stage asked the buyer to give it $21m of preference shares instead of cash.
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The tax benefit was that the initial exchange would qualify as a tax free share for share exchange and after 12 months the prefs would qualify for SSE and so could be redeemed tax free (the original shares did not qualify as they had no dividend rights)
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