Taxation of Chargeable Gains Act 1992 section 169VG

Shares treated as disposed of in previous disposal: no claim made

Section 169VG sets out the ordering rules for determining which shares within a holding are treated as having been disposed of in a previous disposal where no investors' relief claim was made.

• Excluded shares are treated as disposed of first, up to the maximum of either all excluded shares in the holding or the number of shares actually disposed of, whichever is lower.
• If excluded shares do not account for the full disposal, potentially qualifying shares are treated as disposed of next, with later-acquired shares deemed disposed of before earlier-acquired ones.
• If a shortfall remains after allocating excluded and potentially qualifying shares, qualifying shares are treated as making up the difference.
• The ordering priority is therefore: excluded shares first, then potentially qualifying shares (latest acquired first), and finally qualifying shares.