My understanding on working out Share Pool Price

Hi all,

I work for a US tech company, which offers RSU’s as part of their compensation.

Each vesting window, I am given a certain amount of RSU’s (to which nearly half are sold to cover UK Income Tax and National Insurance). I am then given the remainder.

I have been issued RSU’s since 2019 and have never sold them. I am planning on selling these in the next vesting period, however, I would like to confirm if my understanding of the “Share Pool Price” or the Section 104 Rule is correct:

Date of Vest Share Price at time of vest Quantity (the remainder given after the IT and NI) Total Share Value (USD) Total Share Value (GBP) - the rate used for USD > GBP Conversion is the rate at the time of vest

To get the Share Pool Price, I’d:

Add up all of the Total Share Value figures

Divide that by the total number of Shares I hold

That would give me my Share Pool Price.

When it comes to selling these shares and calculating the Capital Gains Tax, I would base the cost of each share on the Share Pool Price that I calculated above.

Is this correct