Income Tax Act 2007 section 321

Power to facilitate mergers of VCTs

Section 321 grants the power to make regulations that facilitate the merger of two or more venture capital trusts (VCTs), provided the merger meets certain conditions.

  • Regulations may be made under section 322 to cover situations where two or more VCTs merge
  • Each merging company must be a VCT immediately before the merger begins to take effect
  • The merger must be carried out for genuine commercial reasons and must not be part of an arrangement whose main purpose, or one of whose main purposes, is the avoidance of tax
  • The regulations will specify the particular cases and conditions (including any required approvals) under which the provisions apply

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