VCM69100 - VCT: winding-up: chargeable gains exemption for VCT-in-liquidation

SI2004/2199 Regulation 5: TCGA92/S100

TCGA92/S100 (1) ensures that capital gains arising to a VCT are treated as not being chargeable gains for the purposes of corporation tax in respect of chargeable gains ( VCM60020), nor are capital losses arising in such circumstances allowable losses for such purposes (this follows from TCGA92/S126 (2)).

Regulation 5 of SI2004/2199 extends that treatment to gains and losses arising to a VCT-in- liquidation ( VCM69010) during its prescribed winding up period ( VCM69020) on disposals of assets it acquired before the commencement of the winding up.

Any gains and losses that arise to the VCT-in-liquidation on the disposal of assets that were acquired by the company or its liquidator after the commencement of the winding up are not covered by the Regulation 5 exemption.