Commentary

D7.449 Gains from VCIPs—scope

Corporate tax
Corporate tax | Commentary

D7.449 Gains from VCIPs—scope

Corporate tax | Commentary

D7.449 Gains from VCIPs—scope

The legislation applies to investments held by a life insurance company for the purposes of its long-term business as a limited partner in a VCIP. To qualify as a VCIP, the partnership must meet three conditions:

  1.  

    (a)     its sole or main purpose, as evidenced by its partnership agreement or prospectus issued to potential investors, must be to invest in unquoted shares and securities

  2.  

    (b)     it must not carry on a trade; and

  3.  

    (c)     no less than 90% of the book value of its investments must be shares or securities that were unquoted at the time of

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