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HMRC internal manual

Venture Capital Schemes Manual

VCT: investor CG disposal relief: share pooling

TCGA92/S151B (1)

The ordinary share identification rules do not apply to VCT shares whose disposal will be exempt from CGT. The ‘last in first out’ and other rules introduced by FA98 do not apply. It is possible for a taxpayer to hold shares in the same VCT some of which do and some of which do not qualify for the CGT exemption. For example:

  • shares may be acquired in excess of the permitted maximum for the year,
  • shares may have been acquired before the date of approval as a VCT.

The normal pooling rules apply to non-exempt shares acquired before 6 April 1998.