PART 1Direct taxes
Income tax: investments
13VCTs: exchange of non-qualifying shares and securities
1
Section 330 of ITA 2007 (power to facilitate company reorganisations etc involving exchange of shares) is amended as follows.
2
After subsection (1) insert—
1A
The Treasury may by regulations make provision for the purposes of this Part for cases where—
a
a holding of shares or securities that does not meet the requirements of Chapter 4 is exchanged for other shares or securities not meeting those requirements, and
b
the exchange is made for genuine commercial reasons and does not form part of a scheme or arrangement the main purpose or one of the main purposes of which is the avoidance of tax.
3
In subsection (2), for “subsection (1)” substitute “subsections (1) and (1A)”.
4
In subsection (3), for “The regulations” substitute “Regulations under subsection (1)”.
5
After subsection (3) insert—
3A
Regulations under subsection (1A) may, among other things, make provision—
a
for the new shares or securities to be treated in any respect in the same way as the original shares and securities for any period;
b
as to when the new shares or securities are to be regarded as having been acquired;
c
as to the valuation of the original or the new shares or securities.
6
In subsection (4), for “The regulations” substitute “Regulations under this section”.
7
In subsection (6). in paragraph (c), at the beginning insert “in the case of regulations under subsection (1)”.