Note that the ‘s. 104 holding’ for capital gains tax purposes is explained at ¶556-825. However, the rules that follow also applied to individuals and trustees for years to 5 April 2008.

For corporation tax purposes, shares or securities of the same class acquired by a person in the same capacity after the end of 1981–82 are pooled together, as a ‘s. 104 holding’ (TCGA 1992, s. 104(1)–(3)) and will be matched according to the identification rules detailed at ¶556-600.

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