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HMRC internal manual

Capital Gains Manual

Share identification rules for capital gains tax from 6.4.2008: treatment of relevant securities

Certain “relevant securities” are not subject to the pooling arrangements. The reintroduction of pooling from 6 April 2008 means that a separate rule is again needed for the purposes of Capital Gains Tax. The TCGA92/S106A(6) rule which identifies disposals against acquisitions on a last in first out (LIFO) basis now applies only to “relevant securities” and these are defined for Capital Gains Tax purposes at TCGA92/S106A(10).

Relevant securities do not form part of a Section 104 holding; TCGA1992/S104(3).