Your World of Legal Intelligence
 United Kingdom | +44 (0) 20 7284 8080

Chapter CRYPTO22255

Document Cited in Related
Vincent
Published date30 March 2021
Record NumberCRYPTO22255
CourtHM Revenue & Customs
IssuerHM Revenue & Customs

This example shows how to the 30 day rule and a part disposal of the section 104 pool interact.

Melanie holds 14,000 token E in a section 104 pool. She spent a total of £200,000 acquiring them, which is her pooled allowable cost.

On 30 August 20XX Melanie sells 4,000 token E for £160,000.

Then on 11 September 20XX Melanie buys 500 token E for £17,500.

The 500 new tokens were bought within 30 days of the disposal, so they do not go into the section 104 pool. Instead, Melanie is treated as having disposed of:

  • the 500 tokens she has just bought
  • 3,500 of the tokens already in the section 104 pool

Melanie will need to work out her gain on the disposal of the 4,000 token E as follows:

Consideration £160,000
Less allowable costs – 30 day (11/09 – 500 token E) (£17,500)
Less allowable costs – S104 (3,500 token E) £200,000 x (3,500 / 14,000) (£50,000)
Gain £92,500

Melanie still holds a...

To continue reading

Request your trial

VLEX uses login cookies to provide you with a better browsing experience. If you click on 'Accept' or continue browsing this site we consider that you accept our cookie policy. ACCEPT