Corporation Tax Act 2010 section 264

Identification of securities or shares on a disposal

Section 264 sets out the rules for identifying which securities or shares are treated as disposed of when an investor sells only part of a holding that includes securities or shares attracting community investment tax relief (CITR).

• When disposing of securities or shares acquired on different days, those acquired on an earlier day are treated as disposed of before those acquired on a later day (first in, first out)
• Where securities or shares were acquired on the same day, those attracting CITR and held continuously since issue are treated as disposed of last
• A holding of securities means securities of the same company carrying the same rights, issued on the same terms and held in the same capacity; a holding of shares means shares of the same class held in the same capacity
• Where a share reorganisation has occurred under section 127 of TCGA 1992, the new shares are treated as having been acquired at the same time as the original shares