RE: RE: DCU Payment29 Sep 2023 20:53
That raises an interesting possibility, fandg2. I can understand that brokers moved the DCUs out of ISAs due to them being a tradable instrument that doesn't meet the ISA requirements. [Yes, I know this has been discussed before and there are differing views on that, but for the purposes of illustrating my main point let's not go back down that rabbit hole].
We can separate the DCU itself - which is like a promise to pay part of the consideration in the future - from the actual payments made which may, possibly, be legitimate receipts into an ISA from a tax perspective. As the DCU entitlement is just a 'deferred' portion of the consideration for buying HUR perhaps it is right that future receipts are still credited to the account type that the shares acquired by Prax were held in when the sale was completed, in the same way as the initial 0.83p was.
If the full consideration at time of completion had included an additional 6.48p up front this would obviously not have been an issue, but that [up to] consideration is instead being phased across 2/3 years. The DCU is then just the vehicle by which they identify who is entitled to receive that deferred consideration.
If the DCUs are traded via Jenkins then it doesn't become a future issue because the new owner will never have held them in an ISA, and so will receive the payments into whichever account they bought them into.
I'm not sure on this, just punting it up for consideration, and good luck arguing that with HMRC if you want to ;)