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HMRC internal manual

Capital Gains Manual

Share identification for corporation tax: relevant securities: held on 31 March 1982 or 6 April 1965

TCGA92/S109 applies to relevant securities in exactly the same way as it applies to shares generally. All securities of the same class in the same company acquired between 7 April 1965 and 5 April 1982 (31 March for companies) were pooled. When indexation allowance was introduced in FA1982 these existing share pools were frozen. It is these pools that Section 109 calls a 1982 holding. See CG50870+.

A taxpayer can make an election under TCGA92/S109 (4) or TCGA92/SCH2/PARA4 to have quoted securities held at 6 April 1965 brought into a 1982 holding at their market value on 6 April 1965. Full instructions can be found at CG51020+.