When there is a disposal of shares it is necessary to identify the shares disposed in order to determine the status of any EIS income tax relief attributable to them. Therefore the general CGT rules for identifying shares disposed (pooling and matching rules), do not apply1.
For the purposes of the CGT exemption, where shares of the same class have been acquired at different times, a disposal is identified with shares issued on an earlier day rather than those issued on a later day (first in, first out)2.
Separate rules governing the CGT exemption are provided to identify disposals of shares issued on the same day (see E3.167 for these rules)3.
The identification rules are appropriately modified where an individual makes an election for alternative treatment of same-day acquisitions after 5 April 2002 and the shares covered by the election include EIS shares, see C2.706.
Historically, shares acquired before 6 April 1998 were not included in a 'pool' with other shares of the same class
Web page updated on 17 Mar 2025 14:18
