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contains a special rule applying to

• relevant companies with a pre-change asset and
• other companies that have acquired a pre-change asset following a disposal to which applied.

It applies to such companies where the pre-change asset consists of a holding of securities to which the share identification rules in apply (CG50500+).

Any new securities acquired after the qualifying change in ownership do not form part of the pre-change asset. Where securities are acquired after the qualifying change of ownership they form a single, pooled asset, separate from those forming the pre-change pool.

Disposals of securities from both a pre-change pool and another pool are identified firstly with the asset that is not the pre-change asset. Where the number of securities disposed of exceeds the number comprised in the other pool, the excess is identified with securities from the pre-change pool. Subject to this general order of priority, all other rules regarding the identification of shares disposed of will continue to apply (CG50500+).

The order of priority explained above cannot be overridden, for example where a sale agreement relates to specifically identified share or bond certificates, provided the relevant securities are all held by the company in the same capacity. This final proviso ensures that a disposal of shares held in a nominee capacity, for example, will only be identified with the total holding as nominee where other shares of the same class are held beneficially.

takes priority over other identification rules in Chapter 1, Part 4 in cases where are capable of taking effect. If is not in point (say because there were no arrangements for the purpose of securing a tax advantage) then the ordinary share identification rules apply (see CG50500+).

defines ‘pre-change asset’ and ‘securities’ for the purposes of new . ‘Pre-change asset’ has the same meaning as for new (see CG47032). ‘Securities’ broadly means any shares or securities of a company, but not relevant securities for the purpose of (qualifying corporate bonds and certain interests in non-qualifying offshore funds).

In common with the ordinary share identification rules in CG50500+, explains that shares or securities of a company are treated as being of the same class where they are, or would be, so treated by the practice of a recognised Stock Exchange.