Commentary

D7.547 Gains from VCIPs—mechanics

Corporate tax
Corporate tax | Commentary

D7.547 Gains from VCIPs—mechanics

Corporate tax | Commentary

D7.547 Gains from VCIPs—mechanics

The rules in this division apply for accounting periods beginning before 1 January 2013. For accounting periods beginning on or after 1 January 2013 see Division D7.4.

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

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