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UK Tax

Section 104 pooling & UK CGT

How HMRC calculates the cost of shares you sell — and how Omnicogi handles it automatically.

What is Section 104 pooling?

Under HMRC's rules (Section 104 of TCGA 1992), all shares of the same class in the same company that you hold are treated as a single pool. Each time you buy more, the new cost is added to the pool. Each time you sell, the allowable cost is calculated as a proportional slice of the current pool — not the original purchase price.

This is fundamentally different from US-style FIFO (first-in, first-out) cost basis. Many UK investors — and even some broker platforms — incorrectly use FIFO, which produces the wrong CGT figure.

Worked example

Building the Section 104 pool for Company XYZ

EventQtyPricePool qtyPool costAvg cost
Buy Jan 2021+100200p100£200.00200p
Buy Aug 2022+200250p300£700.00233.3p
Sell Mar 2023−100300p200£466.67233.3p
CGT calculation for March 2023 sale:
Proceeds: 100 × 300p = £300.00
Allowable cost: 100 × 233.3p = £233.33
Chargeable gain: £66.67

Using FIFO instead would give an allowable cost of £200 (the first 100 shares) and a gain of £100 — a different and incorrect CGT figure for UK purposes.

How Omnicogi handles it

Every time you add a buy transaction, Omnicogi updates the Section 104 pool for that security: adding the quantity and cost, and recalculating the average. Every sell automatically uses the current pool average to compute the HMRC-compliant chargeable gain (or allowable loss).

This happens for all GIA portfolios. ISA and SIPP portfolios don't generate CGT, so pooling is tracked but CGT isn't calculated for those wrappers.

The 30-day rule

HMRC's bed-and-breakfast rules override the Section 104 pool in two situations:

  • Same-day rule — If you buy and sell shares of the same company on the same day, the same-day acquisition cost is used (not the pool average).
  • 30-day rule — If you sell shares and buy them back within 30 days, the re-purchase cost is used as the disposal cost (prevents "bed and breakfasting" to crystallise a gain or loss artificially).

Omnicogi applies these rules in priority order: same-day first, 30-day second, Section 104 pool last. This matches the HMRC-prescribed matching order.

CGT figures in Omnicogi are for personal tracking purposes. Tax law is complex and individual circumstances vary. Always consult a qualified tax adviser before making decisions based on these figures or submitting them to HMRC.