There was a period, following the introduction of new ITEPA 2003, Pt. 7 provisions in 2003, and the subsequent joint Memorandum of Understanding (MOU) between HMRC and the British Venture Capital Association (of 25 July 2003), when HMRC expressed the view that in certain circumstances income tax should be payable on at least part of a manager's share sale proceeds, even where the manager had paid the full unrestricted market value for the shares and otherwise met the conditions set out in the MOU.

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