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HMRC internal manual

Venture Capital Schemes Manual

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HM Revenue & Customs
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EIS: income tax relief: the investor: connection: persons subscribing for shares under certain arrangements

ITA07/S171

An individual is connected with a company if he or she, whether alone or together with any associate (see VCM11100), subscribes for the company’s shares as part of any arrangement which provides for another person to subscribe for shares in another company with which that individual, or any other individual who is a party to the arrangement, is connected within the meaning of VCM11050 to VCM11070.

This provision would apply, for example, where A, B and C own the companies A Ltd, B Ltd and C Ltd respectively, and A subscribes for shares in B Ltd, B in C Ltd and C in A Ltd. If there is reason to believe that such an arrangement exists, under ITA07/S243 any person concerned can be required to give information about it.