Sell VWRL, buy VWRP: is it the same asset for the 30-day rule?

By Jason Bull, a part-time trader who writes about UK capital gains tax for people doing their own returns. 7 October 20269 min readCGT guides

No. VWRL and VWRP are two share classes of one Vanguard fund. The 30-day rule only matches a sale with a purchase of securities of the same class. So a sale of VWRL is worked out against your VWRL pool, whenever you buy VWRP.

Buy VWRD on the same day or in the 30 days after, and the sale is matched. VWRD is VWRL's own share class traded in dollars, with the same ISIN.

The test the law applies

Your Section 104 pool is made of "securities of the same class acquired by the same person in the same capacity". HMRC's outline puts it as shares "of the same class in the same company". The order the rules run in is in how HMRC decides which shares you sold. Units in a unit trust count as shares for all of this.

Shares are not of the same class "unless they are so treated by the practice of a recognised stock exchange". HMRC's manual explains: "A stock exchange lists shares or securities of the same class in a single listing." As a general rule, shares with "different rights or other features which would affect their value" are listed apart as different classes.

In practice the quickest check is the ISIN on your contract note and on the fund's factsheet. One class keeps one ISIN, however many tickers it trades under. That is our reading of the listing rule. Depositary receipts, below, are the exception.

Only a purchase that passes all three tests is matched.

A rebuy by your spouse isn't matched, because the rule reaches only what "the person making" the sale acquires. Nor is a rebuy in your ISA on a later day, which the ISA rules treat as held "in a capacity other than" your other holdings. Our bed and ISA guide covers a SIPP too, and the same-day ISA case the law leaves open.

Common pairs

You sell	Then buy	Same asset?	Why	Source
VWRL	VWRP	No	Two classes of one fund, with two ISINs	CG50203; Vanguard: VWRL, VWRP
VWRL	VWRD	Yes	One class and one ISIN, traded in dollars	s104(1)
Acc units of a UK fund	Inc units, with the cash	No	Different classes	CG57709
Acc units of a UK fund	Inc units, by the manager's switch	Treated as the same asset (no sale)	A reorganisation: cost and date carry over	s103F
A FTSE All-World ETF	Another manager's FTSE All-World fund	No	Two funds, however alike the index	CG51550
GOOG	GOOGL	No	Class C has no vote and Class A has one	CG50203
ULVR	UL, Unilever's ADSs	In HMRC's view, it can be	Shares and receipts over them may be one holding	CG50240

Source: TCGA 1992 s104 and s103F; CG50203, CG51550, CG57709 and CG50240; Vanguard's pages for VWRL and VWRP, read on 29 September 2026; annual reports of Alphabet and Unilever.

Accumulation and income units

HMRC's manual says accumulation and income units "should be treated as different classes of unit". For an OEIC it lists "income shares, net or gross accumulation shares and currency shares" as classes. So if you sell one class and buy the other with the cash, you have sold one asset and bought another. The 30-day rule has nothing of the same class to match it with.

A switch carried out by the fund manager is different. Exchange units for other units in the same fund of "substantially the same value", and the law treats it as a reorganisation. Your share of the fund's capital and income must stay the same, apart from changes in charges. When the manager converts a whole class, that condition does not apply. HMRC's funds manual says the exchange "is treated as not a disposal". So a switch uses none of your £3,000 allowance, and it banks no loss.

Dollar and pound lines of one ETF

Vanguard's page for VWRL shows it on the London Stock Exchange twice. It trades in pounds as VWRL and in dollars as VWRD, and both lines carry the ISIN IE00B3RBWM25. VWRP and VWRA are likewise one class in pounds and in dollars, with the ISIN IE00BK5BQT80.

One class held by you in one capacity is one Section 104 pool. So VWRL and VWRD share a pool, just as VWRL held at two brokers does.

A worked example: VWRP or VWRD after selling VWRL

Say you hold 400 VWRL units in a dealing account. They cost £36,000 in all, which is £90 a unit. You have made no other gains in 2026/27. On Monday 1 March 2027 you sell 100 units at £120, for £12,000. Their share of the pool cost is 100/400 of £36,000, which is £9,000.

A week later the price has slipped to £119. On 8 March 2027 you put £11,900 back into the same fund, choosing one of two tickers.

Buy 70 VWRP units at £170 and nothing is matched, because VWRP is another class. The sale goes against your VWRL pool: £12,000 less £9,000 is a £3,000 gain. The £3,000 tax-free allowance covers it. Your VWRL pool keeps 300 units at £27,000, and VWRP starts a pool of its own at £11,900.

Buy 100 VWRD units instead, paying dollars worth £11,900 on the day. The 30-day rule matches them to the sale. The window runs to 31 March 2027. The gain is £12,000 less £11,900, which is £100. The matched units never join the pool, so the pool still holds 400 units at £36,000.

Rebuy on 8 March 2027	2026/27 gain (£)	Cost carried forward (£)
70 VWRP units, not matched	3,000	38,900
100 VWRD units, matched	100	36,000

Source: TCGA 1992 s104(1); s106A(5) and (5ZA); Capital Gains Tax allowances.

Neither version leaves tax to pay for 2026/27. But buying VWRP carries £2,900 more cost into later years. When those units are sold at a taxable gain, that £2,900 saves £522 at 18% or £696 at 24%. That is the point of selling one class and buying the other: you use this year's allowance and stay invested.

Using the same move to bank a loss is less settled. HMRC's manual says the loss rule in section 16A "should be considered" for a bed and breakfast "involving any asset in order to trigger a capital loss".

Two funds that track one index

Two different funds are never one asset, however alike the index, because they fail one part of the test for a pool: shares "of the same class in the same company". Funds from two managers are normally two companies.

On our reading, two funds inside one umbrella company are different classes of its shares. VWRL and VUSA, Vanguard's S&P 500 ETF, are both shares in Vanguard Funds plc, with two ISINs. Its prospectus divides the company's shares into classes, with "one or more classes of Shares representing a portfolio of assets that makes up a separate Fund".

GOOG and GOOGL

Alphabet has two listed classes. Its annual report says each Class A share (GOOGL) has one vote and Class C shares (GOOG) have no voting rights. Otherwise the rights are identical. HMRC's first example of different classes is "voting and non-voting ordinary shares". So GOOG and GOOGL are two assets with two pools.

ADRs and ordinary shares

For a receipt issued in the UK, HMRC's view is that "the holder of a DR is the beneficial owner of the underlying shares". For a receipt issued abroad, the law of that country decides. Where that law doesn't settle it, HMRC treat the holder as the owner anyway. Only where it says the holder isn't the owner are the receipts a separate asset.

Where you hold "the same class of shares directly and through DRs", HMRC say they "may be regarded as constituting a single holding for share identification purposes". On 28 March 2022, Trading 212 Community member Richard.W wrote that selling GOOG for GOOGL resets your cost. He added: "Similarly, a switch between UL (the US listing of Unilever) and ULVR (the UK listing)."

He was right about GOOG. But UL is Unilever's American Depositary Shares, "each representing one ordinary share". In HMRC's view, UL bought within 30 days of selling ULVR can be one holding with it and so matched to the sale.

The manual says "may", and we have found no HMRC example of receipts under the 30-day rule. Our reading is to treat a switch between a share and its receipt as matched.

Before you switch

Before you sell, put the ISIN on your holding's contract note next to the ISIN of what you plan to buy. If they match, wait 31 days or expect the match. Do the same if one is a receipt over the other.

TaxBull's capital gains tax calculator for shares reads a broker export and shows which purchase each sale was matched to. It pools by the ticker in your file. If you hold one class under two tickers (VWRL and VWRD, say), change one to the other in the transaction list before you calculate. It never matches a depositary receipt with its shares, so work out a switch like ULVR to UL by hand.

Sources

This is general information, not tax advice. The figures here are for 2026/27. Check gov.uk or ask a tax professional about the year you are filing.

Work out your own capital gains tax from your broker exports.

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