[CG51622] Share identification rules for corporation tax: section 104 holding: disposals from the holding
Where a company disposes of all the shares in the Section 104 holding the indexation allowance due is simply the difference between the pool of qualifying expenditure and the indexed pool of expenditure, TCGA92/S110 (3).
Where a company only disposes of some of the shares in the Section 104 holding it is necessary to apportion the allowable cost and the indexation allowance due. Both the pool of qualifying expenditure and the indexed pool of expenditure are apportioned using the same formula. The indexation allowance due on a part disposal is the amount by which the apportioned pool of indexed expenditure exceeds the apportioned pool of qualifying expenditure, TCGA92/S110 (2).