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HMRC internal manual

Capital Gains Manual

Share identification rules for corporation tax: section 104 holding: calls on shares and indexation


This section only applies to the issue of partly paid shares. See CG50207+ for further details on partly paid shares. Most public offers of partly paid shares no longer use the mechanism of a formal call for the outstanding amounts. The shares are usually issued on terms which provide for the outstanding amounts to be paid up by fixed instalments. The company is entitled to indexation allowance on the full amount they are committed to pay from the date the shares are issued as long as the payments are made within twelve months of the issue of the shares. Any payments made after twelve months should be treated as separate amounts of relevant expenditure, TCGA92/S113 (2)(a).