Taxation of Chargeable Gains Act 1992 section 169VD

Disposal where holding consists partly of qualifying shares

Section 169VD deals with how to calculate the portion of a chargeable gain that qualifies for investors' relief when only some of the shares in a holding are qualifying shares at the time of disposal.

• When an individual disposes of shares from a mixed holding containing both qualifying and non-qualifying shares, only a proportionate part of the gain is eligible for investors' relief
• The relievable portion of the gain is determined by multiplying the total chargeable gain by a fraction: qualifying shares divided by total shares disposed of
• Qualifying shares are treated as being disposed of in priority to other types of share, such as potentially qualifying shares or excluded shares
• The number of qualifying shares used in the calculation is capped at the lower of all qualifying shares in the holding immediately before disposal, or the total number of shares actually disposed of