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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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VCT: investor CG deferral relief: share exchanges: where original shares do not have disposal relief

If the original shares do not have disposal relief VCM53090 (c) applies. The deferred gain is treated as accruing if:

  • there is an exchange, reconstruction or amalgamation to which TCGA92/S135 or S136 applies (or would apply but for TCGA92/S116), see CG52579 onwards, also CG53820 onwards, and
  • the new assets held following the exchange, reconstruction or amalgamation are either securities, or are shares which are not ordinary shares in a VCT.