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HMRC internal manual

Venture Capital Schemes Manual

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HM Revenue & Customs
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Share Loss Relief: individual and corporate claimants: individual claimants: a simple case without complications: has there been a disposal?

It is an absolute requirement for a claim to Share Loss Relief that there be a disposal of shares for the purposes of the Taxation of Chargeable Gains Act 1992. This can be an actual disposal by the claimant shareholder, such as a sale of his or her shares, or a deemed disposal. Deemed disposals are events which are not changes of ownership but are treated by the TCGA as if they were actual disposals. In the context of Share Loss Relief the most common deemed disposal is on the occasion of a negligible value claim under TCGA92/S24. There is detailed guidance on negligible value claims at CG13118+. You should note that the making of a negligible value claim is quite separate from the claim to Share Loss Relief: you must be certain, where it is relevant, that a negligible value claim has been properly made and is accepted before you can consider the availability of Share Loss Relief.