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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 TCGA92/S135 or S136 apply


VCM53110 and VCM53120 deal with share exchanges on which the deferred gain is brought back into charge. TCGA92/S135 or S136 may continue to apply if the new shares are ordinary shares in a VCT. The share reorganisation provisions treat these shares as the same shares as the original shares, seeCG52579 onwards. TCGA92/SCH5C/PARA4 (4) preserves the revival of the deferred gain on a later disposal of the new shares.