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
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