Taxation of Chargeable Gains Act 1992 section 169VJ

Disposals of interests in shares: joint holdings etc.

Section 169VJ extends investors' relief to cover situations where a qualifying person disposes of an interest in shares held jointly with others, or where their shares have been pooled under the share identification rules, rather than disposing of a straightforward sole holding.

  • Investors' relief applies not only to disposals of outright holdings of shares but also to disposals of interests in "relevant holdings", which include shares held jointly with others and shares held solely but pooled under the share identification rules.
  • A "relevant holding" is defined as either shares of the same class acquired jointly by two or more persons including the qualifying person, or shares of the same class acquired solely by the qualifying person โ€” in both cases acquired in the same capacity.
  • An "interest" in a relevant holding means the qualifying person's interests in shares within the holding that are treated as a single asset under the share pooling rules, and includes part of such an interest.
  • Where investors' relief applies through this section, related provisions dealing with partly qualifying holdings, trustee disposals, and share reorganisations are adjusted so that references to shares disposed of are read as references to interests in shares disposed of.

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