Income Tax (Earnings and Pensions) Act 2003 section 464

Application to interests in shares

Section 464 sets out how changes in a person's interest in shares are treated for tax purposes, so that any increase or decrease in their interest is treated as a separate acquisition or disposal proportionate to the change.

• Where a person holds an interest in shares rather than the shares themselves, changes to that interest have specific tax consequences.
• An increase in a person's interest in shares is treated as the acquisition of a separate, additional interest proportionate to that increase.
• A reduction in a person's interest in shares is treated as the disposal of a separate interest proportionate to that reduction.
• This rule ensures that partial changes in share interests are taxed appropriately, rather than requiring a complete disposal and reacquisition to trigger a tax event.