VCM47010 - VC loss relief: mixed holdings: introduction

ICTA88/S576 (1)

Taxpayers may have a mixed holding of shares in a company some of which qualify for VC loss relief and some of which do not qualify. For example, some of the shares may have been subscribed for and some may have been purchased. This may present two difficulties when an allowable loss arises on a disposal of the shares:

  • If only part of a mixed holding has been sold, how do you identify whether the disposal is of qualifying or non-qualifying shares - see VCM47050.
  • Once you have identified which shares have been sold, or if the whole of a mixed holding has been sold, how do you quantify the part of the allowable loss that relates to the qualifying shares - see VCM47100.