Some key points on the share identification rules for multiple acquisitions and disposals of shares of the same class are explained by Richard Curtis.
I suspect that most of us have heard of ‘share pooling’, but why ‘pooling’? Perhaps this is because shares are fungible assets – those where the individual units are, in essence, interchangeable and the same.
Filling the bucket
So, adding more shares of the same class to an existing holding is a little like adding a bucket of water to a paddling pool. If the bucket is refilled from the pool, it is certainly not the same water that was poured in, but it does not matter – it’s all water. This is confirmed by TCGA 1992, s 104(1):
‘Any number of securities of the same class acquired by the same person in the same capacity shall for the purposes of this Act
