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Example of disposal of qualifying holding - no new qualifying holdings included in consideration received

A VCT with full approval has qualifying holdings of 拢1.5尘 and total investments of 拢2m. Its qualifying holdings are therefore 75% by value of its total investments

On 10 April 2007 it disposes of a qualifying holding that it has held for more than 6 months. The holding was previously valued at 拢200,000 and is sold for 拢350,000 comprising 拢250,000 in cash and 拢100,000 in loan notes.

-	Qualifying Holdings(QI)	Total Investments(TI)	QI/TI x 100%
Before disposal	拢1.5尘	拢2.0	75%

Disposal: 10 April 2007

Original cost: 拢200,000

Total Proceeds: 拢350,000

Proceeds comprise:

• 拢250,000 in cash (monetary), and
• 拢100,000 in loan notes (non-monetary)

After disposal

Before the application of S280A

拢1.3m 拢2.15m 60%

Applying S280A(2)(a)

The VCT is treated as retaining 100% of the qualifying holding disposed of. It is therefore treated as retaining 拢200,000 (being the original cost) in addition to the actual qualifying holdings of 拢1.3m, making a total of 拢1.5尘 qualifying holdings.

It is also treated as retaining 拢200k for the purpose of its total investments, making total investments before the application of S280A(2)(b) of 拢2.35m.

Applying S280A(2)(b)

The VCT鈥檚 total investments are then treated as reduced by the monetary consideration received, 拢250,000. VCT鈥檚 total investments are therefore (拢2.35M less 拢25O,OOO) 拢2.1尘.

-	Qualifying Holdings(QI)	Total Investments (TI)	QI/TI x 100%
After the application of S280A	拢1.5尘	拢2.1尘	71%

The calculation for the purpose of the 70% qualifying holdings condition will include the deemed retained holding, valued at 拢200,000, and the deemed reduction in the investments of 拢250,000 for 6 months following the date of the disposal of the investment.

These adjustments apply for the full 6 months whether or not the VCT invests or otherwise disposes of the consideration received in that period.