The Investment Trusts and Venture Capital Trusts (Definition of Capital Profits, Gains or Losses) Order 2006
Investment trusts and venture capital trusts are both within the ambit of the corporation tax provisions that apply to loan relationships (see Chapter 2 of Part 4 of the Finance Act 1996 (c. 8)), and to derivative contracts (see Schedule 26 to the Finance Act 2002 (c. 23)). Under those provisions, all profits, gains and losses, including those of a capital nature, are chargeable to corporation tax as income. If no further provision were to be made, therefore, the result would be that capital profits would fall within the charge to corporation tax, even though, before the enactment of those provisions, those profits were outside that charge.