Capital gains tax | Commentary

C2.703 Pooling

Capital gains tax | Commentary

C2.703 Pooling

The general rule regarding pooling is that any number of securities of the same class acquired by the same person in the same capacity are (unless otherwise stated) treated as indistinguishable parts of a single asset (a pool) growing or diminishing as securities of that class are acquired or disposed of1.

This means that the purchases of individual blocks of securities of the same class lose their identity; all the securities in the pool are treated as if they were acquired at the same average cost. A disposal of some of the shares in the pool represents a part disposal of that single asset.

Over the years, various pools have been introduced and varied, but FA 2008, Sch 2, para 84 introduced simplifications which mean that, for capital gains tax purposes, all the capital gains pools

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