Where shares of the same class in the same company have been acquired at different times and at different prices, some form of identification rules are needed to establish which of those shares have been sold, where a sale takes place which is of less than the full amount of the total holding.

On the introduction of capital gains tax in 1965, the question was addressed by the introduction of the ‘pooling’ concept. Under this concept, all shares of the same class in the same company held by the same person in the same capacity were to be regarded as a single asset.

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