VCM68700 - VCT: deferral relief: to whom does
the chargeable gain accrue?
TCGA92/SCH5C/PARA5
Paragraph 5 gives the rules for determining the person to whom
the deferred gain accrues if there is a chargeable event. These
rules are necessary because the original investor may have passed
the shares to their spouse or civil partner on a transfer to which
TCGA92/S58 applied. If there is a chargeable event the gain is
assessable on:
- the person making the disposal,
- the person who holds the shares at the
time of the share exchange or company reconstruction or
amalgamation,
- the person who becomes non-resident,
- the person who holds the shares when the
company's VCT approval is withdrawn,
- the person who holds the shares when the
‘front-end' Income Tax relief is withdrawn or reduced.
