Taxation of Chargeable Gains Act 1992 Schedule 2 paragraph 18

Unquoted shares, commodities etc.

Section 18 sets out the identification rules for unquoted shares and similar fungible assets held on 6 April 1965, using a last in, first out (LIFO) basis for capital gains tax purposes.

• Applies to unquoted shares held on 6 April 1965, but not to quoted securities or shares where a 6 April 1965 valuation election has been made
• When shares of the same class are disposed of, those bought most recently are treated as sold first (LIFO basis), both for matching shares acquired before 6 April 1965 and for distinguishing pre-1965 holdings from later acquisitions
• Shares are only considered to be of the same class if they would be treated as such on a recognised stock exchange, regardless of how they are identified in any actual disposal or transfer documentation
• The same LIFO identification rules also apply to fungible assets other than shares — such as commodities — where individual items are not separately identifiable, but the same-class restriction does not apply to these other assets