Regulation 2 Amendment of the Venture Capital Trust (Winding up and Mergers) (Tax) Regulations 2004

The Venture Capital Trust (Winding up and Mergers) (Tax) Regulations 2004 are amended as follows.

After paragraph (9) of regulation 13 insert—

“(10)

Section 281(1)(f)^f1 applies to a successor company except—

(a)

it does not apply in relation to new shares issued on or after 6th April 2014 which correspond to old shares that were issued before that date, and

(b)

in relation to new shares issued on or after 6th April 2014 which correspond to old shares that were issued on or after that date—

(i)

those new shares are treated as having been issued at the same time as those old shares, and

(ii)

the amount of the successor company’s share capital and share premium in respect of those new shares is treated as the amount of share capital and share premium of the merging company in respect of those old shares.”.