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HMRC internal manual

Community investment tax relief manual

Withdrawal of relief: Identification of securities or shares on disposal

CTA2010/Part 7/Chapter 6/S264; ITA/s377

Where an investor makes a part disposal of a holding of shares or securities to which community investment tax relief has been attributed it is necessary to identify which shares or securities have been disposed of.

In this context a holding means -

  • securities carrying the same rights, and
  • issued under the same terms,


  • shares of the same class,
  • which are held by the investor in the same capacity.

In each case the holding grows or diminishes as the investor acquires or disposes of shares or securities of a similar type.

The identification rules operate on a “first in - first out” (FIFO) principle. Where the holding includes shares or securities that have been acquired on different days, any disposals are treated, for the purposes of both capital gains tax and for the purposes of the CITR scheme, as being disposals of the shares or securities that were acquired earliest. These rules override the normal capital gains tax identification rules.

If securities or shares were acquired, or are treated for capital gains tax purposes as having been acquired, on the same day, any securities or shares to which community investment tax relief is attributable (and which have been held continuously by the investor since they were issued) are treated as being disposed of after any others that were acquired on that day.