EX-8.3 4 f02460a1exv8w3.txt EXHIBIT 8.3 Exhibit 8.3 Inland Revenue REVENUE POLICY BUSINESS TAX CLEARANCE TEAM Fifth Floor 22 Kingsway London WC2B 6NR Ms. Anika Chandra CMS Cameron McKenna TEL 020 7438 7474 Mitre House 160 Aldersgate Street FAX 020 7438 4409 London EC1A 4DD E MAIL reconstructions@gtnet.gov.uk DATE 14 October 2004 www.inlandrevenue.gov.uk OUR REF T1600/4258/04/NR/MD YOUR REF TOL/MT2.17b/101818.00006 Dear Madam: SOLEXA LIMITED Thank you for your letter of 1 October 2004. I have considered the applications made under S707 ICTA 88, S138(1) TCGA 1992. S707 ICTA 88 - TRANSACTIONS IN SECURITIES I am authorised to say that the Board are satisfied that the provisions of S703 (3) ICTA 1988 should not be applied to the proposed transactions. S138 TCGA 1992 - SHARE EXCHANGES AND RECONSTRUCTIONS I am authorised to say that the Board of Inland Revenue are satisfied that the provisions of subsection (1) of Section 137 Taxation of Chargeable Gains Act 1992 should not have effect in respect of these transactions, with the result that Section 135 Taxation of Chargeable Gains Act 1992 would not be prevented from applying. Yours faithfully, /s/ Margaret Draper Margaret Draper Clearance Team Group Leader Information is available in large print, audio tape and Braille formats. Tape Talk service prefix number - 18001 Director: Mary Hay