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HMRC internal manual

Venture Capital Schemes Manual

EIS: disposal relief: investor’s income tax liability reduced to nil

TCGA92/S150A (3)(c)

The restriction does not apply if the only reason full Income Tax relief cannot be given is because the claim reduces the investor’s Income Tax liability to nil. For example, an investor subscribes £100,000 for 100,000 £1 ordinary shares in an EIS company. The investor claims Income Tax relief under ITA07/S158. Only £16,000 worth of relief can be given before their Income Tax liability is reduced to nil, ITA07/S29(2). The restriction in TCGA92/S150A (3) does not apply.