To get the relief you need to ensure that the value of the shares held before the transfer cover the value up to that time and the value of shares issued on the transfer results in the shares issued to the shareholder of D equal to the value he transferred in so as to get the tax relief.

Therefore, the answer to your question depends on the value before and after the transaction. You will have to issue the shares at a nominal value with a share premium. For example – if there are 100 shares before the transaction, and the value of the company is 100k, and the value of the company transferred in is 50k, then shares to issue in M would be 50 shares. The difference between the nominal value per share and the value per share of 1k will not be shown in the accounts, in line with s22.8 of FRS102 and s72 of CA2014. If the provision in s74 of CA2014 is chosen, it will be shown as an “other reserve”.

Note that this “other reserve” does not form part of the company capital, and so it can become distributable when the investment is sold. However, it is not distributable before that point.