Clause 50

in the Part heading, after “ORDINARY SHARES”, insert “OR PREFERENCE SHARES (OR BOTH)”;

in section 13W, in the section heading, after “ordinary shares”, insert “or preference shares”;

in section 13W(1), replace “the divesting VCC” wherever it appears with “divesting VCC 1”;

in section 13W(1)(a), replace “2027” with “2025”;

in section 13W, after subsection (1), insert —“(1A) There is exempt from tax any gains or profits derived by an umbrella VCC (called in this section divesting VCC 2) for the purpose of a sub‑fund from the disposal of ordinary shares or preference shares (or both) in a company (called in this section company Y) or of ordinary shares in a VCC (called in this section VCC Y) that are legally and beneficially owned by divesting VCC 2 for the purpose of that sub‑fund immediately before the disposal, if —

the disposal is made on or after 1 January 2026; and

the disposal is made after divesting VCC 2 has, at all times during a continuous period of at least 24 months ending on the date immediately before the date of disposal of such shares —

legally and beneficially owned (for the purpose of that sub‑fund) at least 20% of the ordinary shares in company Y or VCC Y, as the case may be; or

in the case of company Y only — legally and beneficially owned (for the purpose of that sub‑fund) ordinary shares or preference shares (or both) in company Y the value of which is at least 20% of the total amount of paid‑up share capital of ordinary shares and preference shares in company Y under the applicable accounting principles.”;

in section 13W(2), after “Subsection (1)”, insert “or (1A)”;

in the following provisions, replace “the divesting VCC” wherever it appears with “divesting VCC 1 or 2”:Section 13W(2)Section 13W(3)Section 13W(7)(a);

in the following provisions, after “subsection (1)”, insert “or (1A)”:Section 13W(3)Section 13W(5)(a)Section 13W(7)(a);

in section 13W, replace subsection (4) with —“(4) For the purposes of subsection (1) or (1A), divesting VCC 1 or 2 remains the legal and beneficial owner of any shares in another entity (Y) for the purpose of the sub‑fund mentioned in that subsection during the borrowing period when the legal interest in shares had been transferred by divesting VCC 1 or 2 (as the case may be) to another person under a securities lending or repurchase arrangement.”;

in section 13W(5)(a), replace “company X or VCC X by the divesting VCC” with “company X or Y or VCC X or Y by divesting VCC 1 or 2”; (k)in section 13W(9), after the definition of “activity of holding immovable properties”, insert —“ “applicable accounting principles”, in relation to a company, means —

the accounting principles adopted by the company; or

if the company is not required to comply with any accounting principles in preparing its financial statements — the International Financial Reporting Standards;”; and

in section 13W(9), after the definition of “ordinary share”, insert —“ “preference shares” means only preference shares that are accounted for as equity by the company concerned under the applicable accounting principles;”.