There are four events which may lead to a previously exempted remittance being brought back into charge (see ¶199-900). These are:

(1)the target company ceasing to satisfy Condition A in ¶199-890;

(2)the relevant person (see ¶199-731) who made the qualifying investment makes a full or partial disposal of that holding. If the consideration for a disposal is paid in instalments, each instalment is to be regarded for these purposes as a separate disposal (ITA 2007, s. 809VH(8)). This is in contrast to the capital gains tax rule which treats such a transaction as a single disposal (see ¶515-550);

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