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The Capital Gains Tax (Parallel Pooling) Regulations 1986

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SCHEDULEINTRODUCTORY

In this Schedule—

  • Part I is a statement of facts which are to be assumed;

  • Part II is an application of the Regulations to qualifying securities which are not relevant securities;

  • Part III is an application of the Regulations to qualifying securities which are relevant securities.

PART I

1QUALIFYING SECURITIES AND EXPENDITURE

PG plc held, acquired or disposed of qualifying securities as follows:—

DateNumber of securitiesExpenditure/proceeds
31st March 1982holding1,0006,000
1st September 1982purchased2,00012,000
1st March 1983purchased3,00010,000
1st September 1983rights6,00012,000
1st January 1985sold3,00012,000
31st January 1985purchased3,00010,000

2RETAIL PRICES INDEX

The Retail Prices Index is assumed to be:—

March 1982100 September 1984112
September 1983107 January 1985114
March 1984110 March 1985116

3CALCULATION OF INDEXED POOL OF EXPENDITURE IN ACCORDANCE WITH SCHEDULE 6

Expenditure
SecuritiesExcluded from poolsUnindexed poolIndexed pool
£££
31st March 19821,0006,0006,000
1st September 1983 indexed rise:

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420
Additions to 1983 holding2,00012,00012,000
(Acquired 1st September 1982)
Rights taken up3,0006,000
6,0006,00018,00018,420
1st March 1984 indexed rise:

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516
Addition (including rights) to 1983 holding6,0006,00010,00010,000
12,00012,00028,00028,936
1st September 1984 indexed rise:

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521
Expiry of 12 months following rights issue; expenditure no longer excluded(12,000)12,00012,000
12,00040,00041,457
1st January 1985 indexed rise:

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746
12,00040,00042,203
Disposal3,00010,00010,551
9,00030,00031,652

4SECURITIES HELD LESS THAN ONE YEAR AT 31ST MARCH 1985

The 3,000 securities acquired on 31st January 1985 for £10,000 do not qualify for inclusion in the 1983 holding on 31 March 1985.

PART IIQUALIFYING SECURITIES WHICH ARE NOT RELEVANT SECURITIES

STEP 1—Regulation 5(a)–(c)
Index the indexed pool as if an operative event had occurred immediately before 1st April 1985
Indexed pool (see Part I.3, above)£31,652

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570
£32,222

Therefore—

A = 9,000

B = 30,000

C = 32,222.

STEP 2—Regulation 5(d) and (e)
Number of securities not within 1983 holding (see Part I.4, above)3,000
Relevant allowable expenditure£10,000

Therefore—

D = 9,000 + 3,000 = 12,000

E = 30,000 + 10,000 = 40,000.

STEP 3—Regulation 5(f)
F = 10,000.
STEP 4—Regulation 5(g) and (h)
Number of securities held on 31st March 19821,000
Rights issue 1 for 11,000
G = 2,000
Relevant allowable expenditure on securities= £6,000
Relevant allowable expenditure on rights 1,000 @ £2 per share= £2,000
H = £8,000.
STEP 5—Regulation 6

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= 1,600

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= £6,400
Therefore the 1982 holding comprises:
1,600 shares—relevant allowable expenditure £6,400.
Note: applying the above fraction to the separate components of H (step 4) £4,800 will qualify for indexation from March 1982 and £1,600 from September 1983 for the purposes of section 87 of, and paragraph 5 of Schedule 13 to, the Finance Act 1982.
STEP 6—Regulation 7
Number of securities in the 1983 holding forming part of new holding = 9,000 − 1,600= 7,400
Relevant allowable expenditure on these securities = £30,000 − £6,400= £23,600
Aggregate of relevant allowable expenditure and indexation allowance for the purposes of paragraph 13(2), Schedule 19

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= £26,528.
STEP 7—Regulation 8
Number of securities in new holding = 12,000 − 1,600= 10,400
Qualifying expenditure = £40,000 − £6,400= £33,600
Relevant allowable expenditure in relation to securities not included in 1983 holding= £10,000
Indexation allowance= £180
Indexed pool in relation to the new holding
= £26,528 + £10,000 + £180= £36,708.

SUMMARY

1982 holding: 1600 securities—relevant allowable expenditure £6,400 (of which £4,800 qualifies for indexation from March 1982 and £1,600 from September 1983).

New holding: 10,400 securities—qualifying expenditure £33,600 and indexed pool of expenditure £36,708.

PART IIIQUALIFYING SECURITIES WHICH ARE RELEVANT SECURITIES

STEPS 1–5 as in Part II above.
STEP 6—Regulation 9
Number of relevant securities in 1983 holding not forming part of 1982 holding = 9,000 − 1,600= 7,400
Relevant allowable expenditure

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= £25,348
Expenditure apportioned to securities

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= £3.4254
Deemed date of acquisition of those securities—31st March 1984.

SUMMARY

1982 holding: 1,600 securities—relevant allowable expenditure £6,400 (of which £4,800 qualifies for indexation from March 1982 and £1,600 from September 1983).

Other relevant securities: 7,400 securities treated as acquired on 31st March 1984—relevant allowable expenditure £25,348.

3,000 securities treated as acquired on 31st January 1986—relevant allowable expenditure £10,000.

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