Finance Act 2000
Schedule 15: The corporate venturing scheme
3405.Schedule 15 applies only in relation to shares issued on or after 1 April 2000 but before 1 April 2010 (see section 63(4) of FA 2000). For that reason, Schedule 15 is not being rewritten.
Paragraph 21A
3406.In paragraph 21A of Schedule 15 to FA 2000, this Schedule omits the reference to the second limb of section 776(13)(a) of ICTA, for the reason given in the commentary on this Schedule in relation to that provision.
3407.For the definition of “property deriving its value from land” in paragraph 21A of Schedule 15 to FA 2000, this Schedule substitutes a suitable reference to section 833 of this Act, which, like that paragraph, is a corporation tax provision.
Paragraph 46(2)
3408.Part 6 of Schedule 15 provides for the withdrawal or reduction of investment relief on the disposal of “relevant shares” (as defined in paragraph 2). For the purposes of that Part, paragraph 46(2) lists four types of disposal including:
“(a)by way of a bargain made at arm’s length for full consideration.”
3409.One of the requirements for relief to be available under Part 7 of Schedule 15 on the disposal of shares to which investment relief is attributable is set out in paragraph 67(3):
“(3)The second requirement is that the disposal on which the loss is incurred must be a disposal of the kind described in paragraph (a), (b), (c) or (d) of paragraph 46(2).”
3410.Change 11 in Annex 1 omits the words “for full consideration” from section 244(4)(a) rewritingparagraph 29(4)(a) of Schedule 16 to FA 2002. Section 68(2)(a) also omits those words when rewriting section 575(1)(a) of ICTA for the purposes of share loss relief in this Act.
3411.Paragraph 46(2)(a) of Schedule 15 to FA 2000 is the only other place in the Tax Acts where those words qualify the words “bargain made at arm’s length”. Change 11, therefore, also omits them from paragraph 46(2)(a) for the purposes of both Part 6 and Part 7 of Schedule 15.
