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04 December 2018
Issue: 4675 / Categories: Comment & Analysis

Business investment relief and certificates of tax deposit

What should remittance basis users who dispose of shareholdings acquired under the business investment relief provisions do seeing as no new certificates of tax deposit (CTD) can be made?

These taxpayers can bring foreign income and capital gains into the UK for the purposes of investment in UK companies without triggering a remittance. When the investment is made through the acquisition of shares this is a UK situs asset so any disposal is chargeable for UK capital gains tax purposes.

On disposal the individual has 45 days either to take the proceeds (up to the amount originally invested) offshore or reinvest them in a new qualifying investment. Up to 22 November 2017 the individual could reduce the amount needed to be taken offshore or reinvested by the amount of capital gains tax due on the disposal of the shares as long as it was paid to...

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