Pooling S104 holdings held by husband and wife.

Pooling S104 holdings held by husband and wife.

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The byzantine rules surrounding S104 rules are so complex I do not understand how to deal with the following.

Husband has S104 holdings in companies A,B,C. All created 01/01/2014

Husband and wife have joint S104 holdings in companies A,B,Z all created 01/04/2014

Husband liquidates S104 holdings in B and C and transfers all S104 holdings in company A into the joint S104 pool on 4/04/2014.

How is the joint S104 holding value for company A calculated and how would the 30 day rule operate thereafter?

Why does HMRC make things so ****** complicated!

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By Portia Nina Levin
25th Apr 2015 14:07

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Replying to sash100:
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By James RQL
15th Jul 2014 10:55

Transfer of S104 holdings

Many thanks for confirming what I thought must be the case.

As is happens, Mr and Mrs Jones sold N x A shares for £Q on April 3rd, one day before the transfer from Mr Jones took place on April 4th.

I presume the transfer from Mr Jones into the joint holding is not regarded as a "purchase" under the 30 day rule?

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