The normal identification provisions (see ¶556-500ff.) do not apply to shares to which Seed EIS income tax relief is attributable (TCGA 1992, s. 150E(7)).

Instead the following rules apply:

a disposal is treated as made out of earlier issues before later issues of shares of the same class, i.e. a first in, first out (FIFO) basis; and

where shares of the same class have been acquired on the same day, a disposal is to be identified as comprising:

first, shares which have not been attributed Seed EIS income tax relief, EIS deferral relief or EIS income tax relief;

then to shares to which only Seed EIS income tax relief is attributable;

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