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Tax treatment of return of value on certain shares
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48. The following section is inserted after section 848A of the Principal Act:
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“Tax treatment of return of value on certain shares
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848AA. (1) In this section—
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‘company’ means Vodafone plc;
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‘relevant legislation’ means Part 26 of the Act of the British Parliament entitled the Companies Act 2006;
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‘return of value’ means the special dividend paid in respect of fully paid bonus C shares issued to shareholders in the company in accordance with the terms of a return of value and related share consolidation, provided for by means of a scheme of arrangement under the relevant legislation, and which was completed by the company on or about 21 February 2014.
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(2) Notwithstanding any other provision of this Act, the receipt by an individual who is a shareholder in the company of a return of value in an amount of not more than €1,000, shall be deemed, for the purposes of capital gains tax, to be the receipt of a capital sum derived from the individual’s ordinary shares in the company and not to be income, unless the individual elects to have that return of value treated as income.
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(3) An election referred to in subsection (2) to have a return of value treated as income shall be regarded as made by an individual by including the return of value as income in a return for the year ended 31 December 2014, required to be delivered under section 879 or 959I, as appropriate.”.
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