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HMRC internal manual

Venture Capital Schemes Manual

VCT: investor CG deferral relief: share exchanges: retention of shares

If the chargeable event is an exchange, reconstruction or amalgamation, VCM53090 (c), and the investor retains some of their shares, the guidance on disposals in VCM53170 will apply. In practice this is unlikely. Because VCT shares are quoted or listed the transaction will usually involve all the shares the investor owns and all the deferred gains will be brought back into charge.