CG15087 - Deferred consideration: unascertainable: election for treatment of loss - Condition 1 - chargeable gain postponed
TCGA92/S279A
There is an additional rule where a chargeable gain which satisfies Condition 1, see CG15085, is postponed on account of an investment being made by the taxpayer in shares in VCTs or in qualifying companies under the EIS.
If a 鈥渃hargeable event鈥� occurs in relation to any of these shares, for example some or all of the shares are disposed of, then a chargeable gain, a 鈥渞evived gain鈥�, accrues to the taxpayer. Such revived gains are within Condition 1 unless they are themselves postponed on account of further investments being made by the taxpayer in shares in VCTs or in EIS companies. If this happens, and a chargeable event occurs in relation to those shares, then gains which are the 鈥渞evived gains鈥� on that occasion can fall into this category unless they are themselves postponed in this way. This process continues for any number of successive reinvestments.