Commentary

D7.450 Gains from VCIPs—mechanics

Corporate tax
Corporate tax | Commentary

D7.450 Gains from VCIPs—mechanics

Corporate tax | Commentary

D7.450 Gains from VCIPs—mechanics

Rather than identifying gains on the underlying assets, the investor company treats its interest in the relevant assets of the partnership as a single asset acquired when it became a member of the VCIP1. In this context relevant assets are any assets of the partnership consisting of shares or securities other than qualifying corporate bonds, the latter being excluded because they are not chargeable assets2.

The cost of the deemed single asset is the amount that the investor company contributed as capital on first becoming a member of the partnership. Any further contributions of capital (including interest free loans if all

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial