CG51550 - Share identification rules for capital gains tax from 6.4.2008: outline

Share pooling was reintroduced for disposals on or after 6 April 2008 for those within the charge to Capital Gains Tax. Shares of the same class in the same company acquired at any time by a person in the same capacity will normally become part of the Section 104 holding. »Ê¹ÚÌåÓýapp Section 104 holding is simply the share pool. However, shares that are identified with acquisitions under the ‘same dayâ€� or `bed and breakfastingâ€� identification rules do not become part of the pool.

»Ê¹ÚÌåÓýapp Section 104 holding is a pool of qualifying expenditure as regards the number of shares in the holding.

»Ê¹ÚÌåÓýapp pool grows whenever further shares are acquired that enter the pool and reduces when there is a disposal of shares from the pool. See CG51575 for more detail about how the Section 104 holding operates.

For disposals on or after 6 April 2008 -

  • No indexation allowance is included in any calculation
  • Any shares held on 6 April 1982 are included at their value on 31 March 1982. It is not necessary to consider whether they should be included at their original cost (the “kink testâ€�). CG51570 explains how 1982 holdings are converted into a Section 104 holding.