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HMRC internal manual

Capital Gains Manual

Share identification rules for corporation tax: the 1982 holding: background

1982 holdings were created in 1985 by the operation of paragraph 6 Schedule 19 FA1985.

A company within the charge to corporation tax may still have a distinct 1982 holding and disposals will be identified with this where there are no shares, or no remaining shares, in a section 104 holding. See CG51600.

For a person within the charge to capital gains tax, any 1982 holding will have been converted into a section 104 holding from 6 April 2008, see CG51570.

This guidance was revised in 2014 to set out a brief overview of the pooling rules that applied for both corporation tax and capital gains tax until 1982. If you need to consider the superseded detailed guidance then this is available from commercial tax information packages or directly from Capital Gains Technical Group.

A 1982 holding is now defined for corporation tax purposes as a holding which `was a 1982 holding for the purposes of Part II Schedule 19 FA1985’, TCGA92/S109 (1). Although they were created by FA1985, 1982 holdings have their origins in FA1982.

Put briefly all shares of the same class in the same company acquired between 7 April 1965 and 31 March 1982 (5 April for capital gains tax) were pooled. When indexation allowance was introduced in FA1982 the existing share pools were frozen. It is these shareholdings that FA1985 subsequently called the 1982 holding.