VCM49050 - VC loss relief: companies: introduction

ICTA88/S573

ICTA88/S573 permits investment companies which have allowable losses on disposals of shares in unquoted companies to claim, where certain conditions are met, that the losses should be set against income, rather than against any capital gains.

In many respects the conditions for relief are the same as for a claim to relief by individuals under ICTA88/S574. The following paragraphs regarding VC loss relief for companies should be considered in conjunction with the preceding paragraphs describing VC loss relief for individuals.

In order to decide whether relief can be given on a claim by a company under ICTA88/S573, you will need to consider whether the:

  • shares qualify, see VCM45100 onwards, but note that the statutory provision defining what counts as a subscription is ICTA88/S573 (6), not ICTA88/S574 (3),
  • disposal qualifies, see VCM45800,
  • claimant qualifies, see VCM49100 onwards.

The computation of the amount of the allowable loss that qualifies for VC loss relief follows the same principles as described in relation to claims to relief by individuals, see VCM46000 onwards.

Guidance on how VC loss relief is allowed to an investment company is given at VCM49300 onwards.