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HMRC internal manual

Capital Gains Manual

Venture Capital Trusts: effect

TCGA92/S101C (3), TCGA92/S101C (4), TCGA92/S101C (5)The company is treated as if it had disposed of and reacquired the asset at its market value immediately after the Section 171(1) transfer. Any chargeable gain or allowable loss which would result from this deemed disposal accrues to the company immediately before the time its approval as a Venture Capital Trust takes effect. An assessment for this purpose may be made at any time within 6 years of the end of the accounting period in which approval took effect (including cases where that time was also the beginning of an accounting period). Any recomputations of liability in respect of other disposals, or adjustments of tax by way of discharge or repayment, that may be necessary as the result of the application of Section 101C are to be carried out.