[809VH Meaning of “potentially chargeable event”]
Income Tax Act 2007 (2007 c 3) | Legislation

[809VH  Meaning of “potentially chargeable event”]

[(1)     For the purposes of section 809VG, a “potentially chargeable event” occurs if—

(a)     the target company is for the first time neither an eligible trading company nor an eligible stakeholder company [nor an eligible hybrid company] nor an eligible holding company,

(b)     the relevant person who made the investment (“P”) disposes of all or part of the holding,

(c)     the extraction of value rule is breached, or

(d)     the [5-year] start-up rule is breached.

(2)     The extraction of value rule is breached if—

(a)     value (in money or money's worth) is received by or for the benefit of P or another relevant person,

[(b)     the value is received from any person in circumstances that are directly or indirectly attributable to the investment, and]

(c)     the value is received other than by virtue of a disposal that is itself a potentially chargeable event.

(3)     But the extraction

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