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HMRC internal manual

Venture Capital Schemes Manual

VCT: VCT winding-up: chargeable gains exemption for VCT in-liquidation

SI2004/2199 Regulation 5: TCGA92/S100

TCGA92/S100 (1) ensures that capital gains arising to a VCT are treated as not being chargeable gains for the purposes of corporation tax in respect of chargeable gains (VCM50010), nor are capital losses arising in such circumstances allowable losses for such purposes (this follows from TCGA92/S126(2)).

Regulation 5 of SI2004/2199 extends that treatment to gains and losses arising to a VCT-in-liquidation (VCM56010) during its prescribed winding up period (VCM56020) on disposals of assets it acquired before the commencement of the winding up.

Any gains and losses that arise to the VCT-in-liquidation on the disposal of assets that were acquired by the company or its liquidator after the commencement of the winding up are not covered by the Regulation 5 exemption.