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Contents

Official guidance
Venture Capital Schemes Manual

VCM74000 · Share Loss Relief: individual and corporate claimants: individual claimants

  • VCM74010 · Method of approach
  • VCM74020 · The claims procedure
  • VCM74030 · Giving relief
  • VCM74035 · Limit on income tax reliefs
  • VCM74040 · Priority over other reliefs for losses
  • VCM74050 · Interaction with CGT
  • VCM74060 · Subscription for shares
  • VCM74070 · Qualifying shares and 'eligible shares'
  • VCM74080 · Types of qualifying share
  • VCM74090 · Disposals and deemed disposals
  • VCM74100 · Distributions by a company which are treated as disposals made by its shareholders
  • VCM74110 · Deemed disposals where an asset is lost or destroyed
  • VCM74120 · Deemed disposals where shares have become of negligible value
  • VCM74300 · Type of company invested in: qualifying trading company
  • VCM75200 · When relief is restricted: what to look out for
  • VCM75210 · When relief is restricted: taking account of further acquisitions (mixed holdings)
  • VCM75220 · When relief is restricted: taking account of reorganisations and reconstructions
  • VCM75230 · A simple case without complications
  • VCM75240 · A simple case without complications: has there been a disposal?
  • VCM75250 · A simple case without complications: is it the right sort of disposal?
  • VCM75260 · A simple case without complications: was enterprise investment relief attributable to the shares?
  • VCM75270 · A simple case without complications: are other criteria for qualifying shares met?
  • VCM75280 · A simple case without complications: is the claim valid?
  • VCM75290 · A simple case without complications: giving effect to the claim
  • VCM75300 · More complex cases
  • VCM75320 · More complex cases: inherited shares
  • VCM75330 · More complex cases: bonus shares
  • VCM75340 · More complex cases: shares received under rights issues
  • VCM75350 · More complex cases: shares received in exchange for other shares in a take-over: general
  • VCM75360 · More complex cases: shares received in exchange for other shares in a take-over: conditions for ITA07/S145 and S146 to apply
  • VCM75370 · More complex cases: shares received in exchange for other shares in a take-over: how ITA07/S145 has changed over time
  • VCM75380 · More complex cases: shares received in other reconstructions
  • VCM75390 · More complex cases: disposals of new shares (general case)
  • VCM75400 · More complex cases: mixed holdings and part disposals: introduction
  • VCM75410 · More complex cases: mixed holdings and part disposals: limiting Share Loss Relief: first case
  • VCM75430 · More complex cases: mixed holdings and part disposals: limiting share loss relief: third case
  • VCM75440 · More complex cases: disposal of shares forming part of a mixed holding: introduction
  • VCM75450 · More complex cases: disposal of shares forming part of a mixed holding: general case
  • VCM75460 · More complex cases: disposal of shares forming part of a mixed holding: special case
  • VCM75470 · More complex cases: disposal of shares forming part of a mixed holding: the ‘just and reasonable’ test
  • VCM75480 · More complex cases: disposal of shares forming part of a mixed holding: where an election has been made under TCGA92/S105
  • VCM75490 · More complex cases: disposal of shares forming part of a mixed holding: other points
  • VCM75500 · Deemed time of issue of shares transferred in certain circumstances and corresponding bonus shares
  1. Share Loss Relief: individual and corporate claimants: individual claimants: contents
  2. Share Loss Relief: individual and corporate claimants: individual claimants: deemed disposals where an asset is lost or destroyed

VCM74110 | Share Loss Relief: individual and corporate claimants: individual claimants: deemed disposals where an asset is lost or destroyed

From HM Revenue & Customs · Venture Capital Schemes Manual

TCGA92/S24(1) provides that loss, destruction, dissipation or extinction of an asset is a disposal of the asset for the purposes of the Act, so a chargeable gain or allowable loss can arise at that time. For guidance on this subject, see CG13120P.

Section 131(3)(c) ITA 2007 ensures that a deemed disposal under TCGA92/S24(1) is a disposal for Share Loss Relief purposes, so an allowable loss accruing under TCGA92/S24(1)may be the subject of a claim to Share Loss Relief. This is so for claims made by individuals only in respect of loss or destruction etc occurring after 5 April 2000 (for companies the corresponding date is 31 March 2000): there was no provision corresponding to section 131(3)(c) for earlier deemed disposals of this sort, though a concessionary practice ensured a similar result was possible.

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