CG50241 - Definitions: tax analysis

For capital gains purposes the holder of the DR has two separate chargeable assets, namely

• a beneficial interest in the underlying shares, and
• the DR (being the document evidencing title, and comprising a number of rights as against the depository).

A disposal of shares in DR form is therefore in strictness a disposal of two separate assets. In general, however, the value of a DR may be expected to track closely that of the underlying shares. So the consideration on any disposal may relate entirely, or almost entirely, to the shares themselves. In practice therefore you may not need to make any apportionment of base cost, or consideration received, on a disposal of shares in DR form.