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HMRC internal manual

Venture Capital Schemes Manual

Share Loss Relief: individual and corporate claimants: individual claimants: more complex cases: disposal of shares forming part of a mixed holding: the ‘just and reasonable’ test

ITA07/S148 provides rules for characterising shares disposed of from a mixed holding, and for identifying any qualifying shares disposed of with specific acquisitions of shares. However, there may be exceptional circumstances where none of the rules at section 148 subsections (3) to (6) apply, or they do not give definitive answers. In such cases subsection (7) says that the questions are to be determined ‘on a just and reasonable basis’.

There is no statutory definition of ‘just and reasonable’; the terms should be given their normal meanings.