Corporation Tax Act 2010 section 356JKA

More than one disposal on a single day

Section 356JKA allows a company that makes more than one qualifying equity disposal on the same day, in relation to the same cluster area, to elect the order in which those disposals are treated for the purposes of calculating any transferable allowance.

• The rule applies where a company makes more than one qualifying disposal of an equity share on a single day in relation to the same cluster area
• The company may elect the order of priority in which those disposals are to be taken into account when calculating the amount of allowance available for transfer
• A disposal placed higher in the priority order is treated as a "prior disposal" in relation to any disposal ranked below it, which affects the calculation of the remaining transferable amount
• Once the election is made, it is irrevocable and the chosen ordering cannot be changed