Section 104
regulation
Section 104
The UK's pooled cost-basis rule for shares and cryptoassets under HMRC's Capital Gains Tax framework. Rather than tracking each individual acquisition lot, all units of the same asset are pooled, and disposals are matched against the average cost of the pool. Special 'matching rules' apply for disposals within 30 days of an acquisition (the 'bed-and-breakfasting' rules) and for same-day acquisitions and disposals. The HMRC Cryptoassets Manual explicitly applies Section 104 pooling to crypto holdings.
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