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Two portfolios, one Section 104?

A friend of mine has two offshore S&S accounts/portfolios in France though she's tax resident in the UK. One is a sort of historical accident with just 250 units of one specific ETF (bought a good few years ago) and nothing else. The other has quite a few items and one of those is the same ETF but 1500 units. These units were bought piecemeal a couple of years ago over a period of a few months. Now she wants to sell some of those units. Given this from gov.uk:
Any number of securities of the same class acquired by the same person in the same capacity shall for the purposes of this Act (subject to express provision to the contrary) be regarded as indistinguishable parts of a single asset growing or diminishing on the occasions on which additional securities of the same class are acquired or some of the securities of that class are disposed of.
... am I right in assuming that all these 1750 units (though they reside in separate portfolios) are treated as one single big section 104 investment? Or does the fact that they are in two different (offshore) portfolios create two separate sections? If so, could she select to sell just the 250 units from the first portfolio, close the thing and be happy? (Of course she can do that anyway but if the units are in separate sections the CGT calculation will be different...)

Comments

  • Jeremy535897
    Jeremy535897 Posts: 10,751 Forumite
    10,000 Posts Fifth Anniversary Photogenic Name Dropper
    They are one section 104 pool.
  • That's what I thought but with these things there's always the nagging feeling that I've overlooked some obscure regulation buried somewhere in the unfathomable depths of HMRC's wonderful website.

    Merci beaucoup, Monsieur Jeremy!
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