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HMRC internal manual

Capital Gains Manual

Employee shareholder shares: share identification


The ordinary share pooling and matching rules, sections 104, 105 and 106A TCGA92, do not apply to exempt employee shareholder shares (see CG56715).

If an employee holds shares of the same class in the same company and some, but not all, are exempt employee shareholder shares then, on a disposal of less than all of the shares held, the employee may determine what proportion of the shares disposed of are exempt employee shareholder shares. The disposal consideration is apportioned accordingly.