Taxation of Chargeable Gains Act 1992 section 20

Original market value and aggregate market value for purposes of section 19

Section 20 explains how to determine the "original market value" and "aggregate market value" of assets disposed of in a series of linked transactions, for the purposes of applying the anti-avoidance rule in section 19.

• The original market value of assets in the most recent transaction is their standalone market value; for earlier transactions, it is the value previously used or deemed as consideration before the latest transaction occurred.
• The aggregate market value is determined by imagining all assets from every transaction in the series being disposed of together in a single disposal at the date of the transaction in question — and if treating them as merged into a single asset produces a higher value, that higher value is used.
• Where assets were acquired after the first transaction in the series, they are generally excluded from the aggregate valuation unless acquired via an intra-group transfer, and the total number of assets considered is capped at the maximum held at any point between the first and last transactions.
• Where the assets are securities or fungible assets, disposals are matched to earlier acquisitions first (i.e. a first-in, first-out identification rule applies).

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