| Commentary

52.3.2 Present position

| Commentary

52.3.2 Present position

Subsequently, two events occurred to provide clarity in this area. First of all, on 25 July 2003 HM Revenue and Customs and the British Venture Capital Association (BVCA) agreed the text of a memorandum of understanding on the income tax treatment of managers’ equity investments in venture capital and private equity backed companies1. Secondly, HMRC received counsel’s opinion that a charge under the post-acquisition benefits provisions of Chapter 4 was not sustainable in relation to a ratchet where the benefit to the holder of the shares reflected rights already present in that class of share

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