CG13370 - Bed and breakfasting: shares and securities

The bed and breakfast deal you are most likely to see in practice is the sale and repurchase of shares. The share identification rules mean that the disposal and repurchase must not take place on the same day. This is because TCGA92/S105 (1)(b) matches disposals first against acquisitions made on the same day, including acquisitions made after the disposal(1)(b), see CG51560 (CGT) and CG51610 (Corporation Tax)+. So even if there was a disposal, a reacquisition of the shares on the same day would not give rise to any significant gain or loss.

The capital gains tax rules also match a disposal of shares with any acquisition in the following 30 days. See CG51560.

Note that the share identification rules apply to all assets that usually dealt in without having to identify the individual asset. See CG51500.

Where there is an agreement to buy back the shares at the time of disposal then the repo rules may mean that there is no disposal at all for capital gains purposes, see CG13360.