Sign-in Help
Commentary

52.5 HMRC’s current guidance on ratchets

COMPANIES vol 11 acquisitions, mergers, demergers
| Commentary

52.5 HMRC’s current guidance on ratchets

| Commentary

52.5 HMRC’s current guidance on ratchets

HMRC state1 that where shares are acquired under arrangements consistent with those described in Sections 1–5 of the BVCA/HMRC 2003 Memorandum then, where there is a ratchet operating at an ‘exit’, no Chapter 4 benefit charge will arise on the disposal of those shares or, if earlier, on operation of the ratchet. Where in addition, the ratchet meets all the conditions in paragraph 6(2)(a) and (b) of the Memorandum, any gains realised on exit will be subject to capital gains tax only and not to income tax and national insurance contributions. Where

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to LexisLibrary or register for a free trial
EXISTING USER? SIGN IN TAKE A FREE TRIAL TAKE A FREE TRIAL
Stop drafting from scratch and work more productively.
Offering an unrivalled collection of non-litigation precedents for everything specialist and generalist practitioners are likely to encounter.
TAKE A FREE TRIAL Take a free trial Take a free trial