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HMRC internal manual

Venture Capital Schemes Manual

From
HM Revenue & Customs
Updated
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VCT: investor CG disposal relief: shares acquired in excess of permitted maximum: same day acquisitions

A single acquisition may consist of some shares which qualify for exemption and some shares which are acquired in excess of the permitted maximum. In relation to shares acquired on the same day, TCGA92/S151A(4)(b) provides that disposals are identified first against the shares acquired in excess of the permitted maximum.

Take the example in VCM52090. In September 1996 the taxpayer bought 60,000 shares on the same day, 50,000 of the shares qualify for exemption and 10,000 do not. Disposals are identified first against the 10,000 shares.

Therefore if the taxpayer sold 70,000 shares in 1999 the disposal would be identified as follows:

50,000 shares acquired May 1996 exempt
   
10,000 shares acquired September 1996 not exempt
10,000 shares acquired September 1996 exempt