PLN Tax
Pantheon International Participations PLC
Pantheon International Participations PLC (the 'Company') draws the attention
of noteholders to the following developments in relation to the tax treatment
of participating loan notes of the Company ('PLNs').
Holders of PLNs which are companies within the charge to UK corporation tax
should note that, following changes to the law confirmed in the Budget on 17th
April 2002 and contained in the Finance Bill 2002, any payment received in
respect of PLNs (whether on any redemption or other disposal) in respect of the
period after 26th July 2001 will be brought into account under the loan
relationship rules (and not as chargeable gains.)
Individuals and other holders should not be affected by the above. Investment
trust holders may be unaffected depending on their accounting treatment of
payments received.
The Company also announces that there is currently uncertainty regarding the
tax treatment of payments received by noteholders who are subject to tax on
distributions, such as individuals, on redemption of their PLNs. The Inland
Revenue has stated that most of any amount received on redemption that is in
excess of 30 pence (being the guaranteed minimum adjusted redemption value of
the PLNs and therefore, in the Inland Revenue's view, the 'principal secured'
for tax purposes) should be treated as a distribution and taxed as income in
the same way as dividends. This would lead to the result that such holders may
be taxed on receipts representing amounts originally subscribed. Although in
such a case holders should realise a corresponding loss for capital gains tax
purposes, the capital loss would not be available to be set off against the
distribution. If the Inland Revenue are correct, holders may therefore be taxed
on amounts which do not represent profit on their investment. In any event,
gains on sales of PLNs through the market will continue to be taxed as capital
gains in the normal way.
It is the view of the Company's tax advisers, supported by Counsel's opinion
obtained in connection with the implementation of the PLN structure in May
2000, that only any amount received that is in excess of the amount originally
subscribed for a PLN will represent a distribution. There is nothing in the
Finance Bill 2002 that affects the previous analysis of the Company's tax
advisers. Therefore, the Company intends to dispute the point further with the
Inland Revenue. Further information will be made available to noteholders in
due course.
Enquiries:
Alastair Bruce Tel: 020 7484 6200
Pantheon Ventures Limited
pip@pantheon.co.uk
Latest directors dealings
- 1 day ago Savannah Energy
- 1 day ago Buccaneer Energy PLC
- 1 day ago Savannah Energy
- 1 day ago Carclo
- 1 day ago Schroder Japan Growth Fund