Commentary

D2.406 Pre-change assets—Pooling

Corporate tax
Corporate tax | Commentary

D2.406 Pre-change assets—Pooling

Corporate tax | Commentary

D2.406 Pre-change assets—Pooling

Special rules are required to deal with pre-change assets which are securities of the same class held in a pool. In effect, separate pools are maintained for securities acquired before and after the change in ownership and for securities held by the company in different capacities, eg as nominee or trustee1.

A disposal of a pooled security at or after the time of the change is matched:

  1.  

    •     first with securities in the pool of assets acquired after the change

  2.  

    •     next with securities in the pre-change pool

  3.  

    •     subject to that, in accordance with the rules in

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