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HMRC internal manual

Capital Gains Manual

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HM Revenue & Customs
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Assets disposed of: assets acquired after series of transactions started

TCGA92/S20 (6)

Some of the assets disposed of in the linked series of transactions may have been acquired after the first transaction in the series. If that is so, in relation to each transaction in the series

  • you should not take account of any asset which was acquired after the date of the transaction concerned and
  • the number of assets of which you may take account is limited to the maximum number held by the person making the disposal at any date in the period beginning immediately before the first transaction in the series and ending immediately before the last of the transactions.

Special rules apply for groups of companies. See CG14700+.

Mrs B acquires all the issued share capital in an unquoted company as follows:

September 1990 500 shares
   
May 1991 200 shares
December 1992 300 shares

She transfers shares to her son as follows:

April 1991 400 shares
   
June 1993 200 shares

The transfers constitute a series of linked transactions.

In arriving at the aggregate market value as at April 1991, you would take no account of the 200 shares acquired in May 1991. The maximum number to be taken into account on that occasion would be limited to the 500 shares held immediately before April 1991.

When considering the aggregate market value at June 1993 the maximum number of shares to be taken into account would be limited to the 600 shares held immediately before June 1993.