In general, shares or securities of a company being of the same class and held by one person in one capacity are regarded as indistinguishable parts of a single asset ('a holding') so that the sale of a part of the holding is treated as a part disposal1. This general 'pooling' rule is subject to two exceptions in the case of transactions involving the same class of share held by the same person in the same capacity. First, disposals on or before acquisitions made the same day are treated as a single transaction2. Second, the capital gain/loss on disposals
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