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Home / Simons-Taxes /Personal and employment tax /Part E3 Reliefs for investors /Division E3.2 Venture Capital Trust schemes (VCTs) /VCTs—company conditions / E3.241 Mergers of one VCT with another VCT company or group
Commentary

E3.241 Mergers of one VCT with another VCT company or group

Personal and employment tax

For merger transactions taking place after 16 April 2002, regulations enable investors in VCTs to retain their tax reliefs when the VCT in which they have invested merges with another VCT1. VCTs may retain approval when they merge with each other, subject to certain conditions.

Types of VCT merger

There are two types of merger between one merging company (VCT1) and another merging company or companies (VCT2).

Types of VCT mergerCommentary
A section 323(1) merger2.This is where shares in VCT1 are issued to members of VCT2 in exchange for the shares they held in VCT2, and the new shares in VCT1 which those members acquire are received in exchange for their shares in VCT2, or by way of consideration for the transfer of the whole or part of the business of VCT2 to VCT13.
A section 323(2) merger4.This is where the members of the merging companies exchange their shares for shares in a new VCT. This would be

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