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HMRC internal manual

Capital Gains Manual

From
HM Revenue & Customs
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Share identification rules for corporation tax: same day acquisitions

All shares of the same class in the same company acquired by the same person on the same day and in the same capacity are treated as though they were acquired by a single transaction, TCGA92/S105 (1)(a).

All shares of the same class in the same company disposed of by the same person on the same day and in the same capacity are treated as though they were disposed of by a single transaction, TCGA92/S105 (1)(a).

If there is an acquisition and a disposal on the same day the disposal is identified first against the acquisition on the same day, TCGA92/S105 (1)(b). No indexation allowance can be given on this transaction.

If the number of shares disposed of exceeds the number acquired on the same day the disposal must be identified in the order set out in CG51600.

If the number of shares acquired exceeds the number sold on the same day the surplus creates or goes into a Section 104 holding, see CG51620+, and is an operative event, assuming that there is no disposal within the next ten days, see CG51615-6.