UUֱ

Share matching rules

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance

Share matching rules

Produced by a Tolley Corporation Tax expert
Corporation Tax
Guidance
imgtext

This guidance note explains the specific rules that apply on the disposal of shares by a company. If shares of the same class in the same company have been acquired on various occasions for different amounts, it is necessary to follow the specific rules to ensure that the disposals are matched with the relevant acquisitions.

Disposals are matched with acquisitions in the following order:

  1. shares acquired on the same day as the disposal

  2. shares acquired in the previous nine days on a first in, first out basis

  3. shares from the section 104 pool

  4. shares from the 1982 holding

  5. shares purchased before 1965 on a last in first out basis

  6. shares purchased after the date of disposal in order of acquisition

TCGA 1992, ss 105, 107

The disposal of shares may fall within the scope of the substantial shareholding exemption (see the Cases in which SSE applies guidance note). Where the disposal meets the relevant criteria, the shares to be disposed of are still identified using the above matching rules.

HMRC

Access this article and thousands of others like it
free for 7 days with a trial of Tolley+™ Guidance.

Powered by

Popular Articles

Payment of the remittance basis charge

Payment of the remittance basis chargeRemittance basis chargeThe remittance basis charge is an annual charge payable by ‘long-term’ UK residents for the privilege of claiming the remittance basis.Taxpayers who wish to utilise the remittance basis (but do not qualify for it automatically) must pay

14 Jul 2020 12:52 | Produced by Tolley Read more Read more

Payroll record keeping

Payroll record keepingUnder SI 2003/2682, reg 97, “...an employer must keep, for not less than 3 years after the end of the tax year to which they relate, all PAYE records which are not required to be sent to [HMRC]...”. Reasons for keeping the records include:•being able to calculate tax and

14 Jul 2020 12:52 | Produced by Tolley in association with Ian Holloway Read more Read more

Indexation allowance and rebasing

Indexation allowance and rebasingThis guidance note explains the general rules surrounding the availability of indexation allowance (which was frozen at December 2017) on the disposal of company assets and provides information on the rebasing rules for assets held on 31 March 1982. For an overview

14 Jul 2020 11:59 | Produced by Tolley in association with Jackie Barker of Wells Associates Read more Read more