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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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EIS: income tax relief: withdrawal or reduction of EIS relief: value received by the investor: amount of value received

ITA/S216 (6); ITA/S217

An individual is also regarded as receiving value if a person connected with the company (see VCM11050 onwards):

  • purchases any of the share capital or securities of the company which belong to that individual or an associate of his,


  • makes any payment to him or his associate for giving up any right in relation to such share capital or securities.

The value received is the amount received or, if greater, the market value of the shares or securities.


A subscribes £2000 for eligible shares in a company and £1100 for loan stock of the same company. A obtains income tax relief on £2000. B, a paid director of the company, then buys the loan stock, which has a market value of £1100, for £1000, thus in effect obtaining a share of A’s tax relief.

The rule in ITA07/S216(6) and ITA07/S217 reduce the amount on which relief is available to A by £1100.

It should be noted that the rule applies whether the sale of shares precedes or follows the subscription for the shares on which relief is claimed, and applies to any types of share capital or securities, for example, preference shares or debentures.