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HMRC internal manual

Residence, Domicile and Remittance Basis Manual

HM Revenue & Customs
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Remittance Basis: Exemptions: Business investment relief: Record keeping

The onus of proof is on the person claiming business investment relief. If there is a claim to the relief, appropriate evidence should have been kept which will:

  • support the initial claim to the relief, for example

    • how much was invested
    • when the investment was brought to the UK
    • when and in which company the investment was made
    • if a chargeable event occurred, the actions taken, for example if an investment was not proceeded with, the amount returned overseas,

and show that it continues to be a valid claim throughout the life of the investment, for example that the company being invested in meets, and continues to meet, relevant conditions.

For example, if payments or other benefits are received from the company in which the investment occurred, there should be sufficient proof to show that these occurred on arm’s length terms.