Commentary

D7.452 Gains from VCIPs—miscellaneous issues

Corporate tax
Corporate tax | Commentary

D7.452 Gains from VCIPs—miscellaneous issues

Corporate tax | Commentary

D7.452 Gains from VCIPs—miscellaneous issues

These rules have no effect on the operation of the Offshore Funds (Tax) Regulations 20091 however any disposal proceeds resulting from a distribution from such a VCIP are reduced by the amount of any offshore gain accruing to the company thus preventing double taxation2.

The investment that is the single deemed asset may not be subject to a negligible value claim under TCGA 1992, s 24(2)3.

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