Taxes Consolidation Act 1997 section 545A

Share disposals and central securities depositories

Section 545A provides that the migration of shares from a UK central securities depository to an EU depository following Brexit does not constitute a disposal for capital gains tax purposes, and sets out how co-ownership interests in pooled shares are treated.

• The transfer of shares under the Migration of Participating Securities Act 2019 is not treated as a disposal for CGT purposes.
• Where a central securities depository requires holders to hold interests by way of co-ownership in a fungible pool of underlying shares, special rules apply.
• A disposal of a co-ownership interest in pooled shares is treated as a disposal of the person's interest in the underlying shares.
• References to "shares" in certain CGT provisions are deemed to include references to co-ownership interests held through a central securities depository.