Commentary

E1.536 Treatment of shares where annual limit exceeded

Personal and employment tax

E1.536 Treatment of shares where annual limit exceeded

E1.536 Treatment of shares where annual limit exceeded

In order for VCT dividends to be exempt from income tax, Condition B (see E1.535) provides that the acquisition of the VCT shares should not have caused the annual limit to be exceeded1.

However, if shares of different descriptions acquired on the same day cause the limit to be exceeded on that day, shares of each description are treated as exempt shares so far as their market value does not exceed 'the appropriate proportion' of 'the available value'2. In relation to shares of a particular description, 'the appropriate proportion' means the proportion that

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