Taxation of Chargeable Gains Act 1992 section 184F

Sections 184A and 184B: "pre-change assets": pooling rules

Section 184F establishes special share pooling and identification rules that apply when a company holds pre-change pooled securities and subsequently acquires further securities of the same class, ensuring that the pre-change pool is kept separate from later acquisitions for the purposes of the loss-buying and gain-buying restrictions in sections 184A and 184B.

• Securities acquired after the relevant time must not be added to a pre-change pooled asset; instead they form a separate pool (the "other pooled asset")
• When securities of the same class are disposed of, they must be matched first against the other pooled asset, and only the excess is matched against the pre-change pool
• These identification rules override normal share matching rules and cannot be circumvented by specifically identifying certificates, although securities held in different capacities (e.g. beneficial versus nominee) are not matched against each other
• The rules apply to pre-change assets held by the relevant company and to those acquired through intra-group no gain/no loss transfers, and "securities" for this purpose excludes qualifying corporate bonds and certain non-qualifying offshore fund interests