C2.718 Securities held at 31 March 1982
The legislation described in this article does not apply for corporation tax purposes to securities acquired before 6 April 1965 unless an election was made to include them in the 1965 pool (see C2.719). It does not apply to capital gains tax disposals after 5 April 2008.
The general rule is that the acquisition cost of unmatched securities in the 1965 pool (see C2.703) is taken as the market value of those securities on 31 March 19821. The only additions to that pool after 31 March 1982 are bonus or scrip issues related to securities already in the pool, which are treated as acquired on the same date as the securities to which they relate2.
The securities in the 1965 pool are regarded as a single asset3.
Where the securities in the 1965 pool are valued at 31 March 1982, the value of unquoted securities issued by a company may depend on the proportion of issued securities of the class concerned which is held by the taxpayer (different rights may apply according to the proportion held). For this reason, HMRC operated a concession under which the number of such securities acquired before April 1965 could be taken into account in the determination of market value at April 19824.
Where a disposal is matched with the 1965 pool, it is normally necessary to make two computations (the kink test):
(a) taking the acquisition cost as the market value at 31 March 1982, and
(b) taking the acquisition cost