CG50574 - Share identification rules: CGT treatment of shares from 6.4.98: different holdings for CGT

After 5 April 1998 taxpayers can have different holdings of shares of the same class in the same company held in the same capacity. They may be

• acquisitions on or after 6 April 1998, each one being separate(subject to the same day rule), see CG50572
• a Section 104 holding, see CG50590+, treated as acquired when the holding first came into existence
• a 1982 holding, see CG50870+, treated as acquired on 31 March 1982
• shares held at 6 April 1965, see CG50970+.

It is necessary to keep these holdings separate because of the specific order in which disposals of shares after 5 April 1998 are to be identified with acquisitions, see CG50564.

The date when any Section 104 holding came into existence will also be relevant for determining whether the holding qualifies for the `bonus year' for taper relief, see CG17901. If that date is before 17 March 1998 the entire holding can qualify for the bonus year, even if some of the shares in the holding were acquired on or after 17 March 1998.