Are VCT dividends taxable on an estate?

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I'm trying to determine whether the tax relief on VCT dividends extends to an estate where the individual held VCT investments and dividend income was received in the period of adminsitration. Looking at the legislation (ITTOIA 2005, s709) it would appear that the answer is no, as condition A states the person beneficially entitled to the dividend is an individual. In my case, this was not a specific legacy so the income is attributable to the estate and not an individual, hence condition A is not satisfied and the dividends are taxable. Is my thinking correct? Thanks. 

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By taxadvisercarlisle
30th May 2023 09:41

Just an update - I found the following guidance which seems to suggest I am wrong

https://www.lexisnexis.com/uk/legal/results/enhdocview.do?docLinkInd=tru...

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By SSM
31st May 2023 10:39

I'm not a tax expert, but your interpretation of ITTOIA 2005, s709 seems to be correct. The tax relief on VCT dividends appears to be restricted to individuals who are beneficially entitled to the dividend. In the case of an estate, the income would be attributable to the estate rather than an individual, making it unlikely that the tax relief would apply to the dividends received during the period of administration.

However, please note that this information is for general purposes only and should not be considered specific tax advice. It is essential to consult with a professional tax advisor for guidance on your individual circumstances and the latest applicable tax laws.

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Replying to SSM:
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By Taxguy96
31st May 2023 12:22

ChatGPT is that you?

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Replying to Taxguy96:
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By Hugo Fair
31st May 2023 12:40

And so it starts .. the doubts, uncertainties, recriminations ... dystopia beckons!

But I know what you mean ... take chunks of text / re-order them / then publish.

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Replying to Hugo Fair:
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By Taxguy96
31st May 2023 13:46

I have played about with ChatGPT out of curiosity, and it was the final paragraph in the comment which looked to give it away to me!

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