FORESIGHT 4 VCT PLC - Foresight Group

PART VIII
TAX POSITION OF SHAREHOLDERS
The following paragraphs apply to the Company and to persons holding Shares as an investment who
are the absolute beneficial owners of such Shares and are resident in the UK. They may not apply to
certain classes of persons, such as dealers in securities. The following information is based on current
UK law and practice, is subject to changes therein, is given by way of general summary and does not
constitute legal or tax advice.
If you are in any doubt about your position, or if you may be subject to a tax in a jurisdiction other than the
UK, you should consult your independent financial adviser.
The tax reliefs set out below are available to individuals aged 18 or over who receive Shares under the
Scheme.
The Company
The Company has obtained approval as a VCT under Chapter 3 of Part 6 ITA 2007.
The Board considers that the Company has conducted its affairs and will continue to do so to enable it to
qualify as a VCT.
The Scheme
The effective exchange of Target VCTs’ Shares for New Shares will not constitute a disposal of such
shares for the purposes of UK taxation. Instead, the new holding of New Shares will be treated as having
been acquired at the same time and at the same cost as the existing Target VCTs’ Shares from which
they are derived. Any capital gains tax deferral relief obtained on subscription of the existing Target
VCTs’ Shares will not, therefore, be crystallised for payment, but will be transferred to the New Shares.
For Target VCTs’ Shareholders holding (together with their associates) more than 5% in the share
capital of any one of the Target VCTs, clearance has been obtained from HMRC in terms of Section 138
of TCGA 1992 that the treatment described above for persons who (together with their associates) own
less than 5% of the share capital of any one of the Target VCTs will also apply to them.
The implementation of the Schemes will not affect the VCT status of the Company as a VCT or the
reliefs obtained by Shareholders on subscription for existing Shares. Although the Company will be
required to pay UK stamp duty or stamp duty reserve tax on the transfer to it of the assets and liabilities
of the Target VCTs (which form part of the estimated merger costs being allocated to the Company and
the Target VCTs), no UK stamp duty or stamp duty reserve tax will be payable directly by Shareholders
as a result of the implementation of the Scheme.
Shareholders not resident in the UK
Shareholders not resident in the UK should seek their own professional advice as to the consequences
of making and holding an investment in a VCT as they may be subject to tax in other jurisdictions as well
as in the UK.
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