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HMRC internal manual

Venture Capital Schemes Manual

From
HM Revenue & Customs
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EIS: disposal relief: mixed holdings

TCGA92/S150A (6)

A taxpayer may hold shares in a company in respect of which EIS Income Tax relief, or SEIS Income Tax relief, has been given (and not withdrawn) on some of the shares but not on others. If there is a bonus issue in respect of these shares the share reorganisation rules apply to each holding separately. Therefore the new shares are allocated to each separate holding and there is no question of shares that have attracted EIS Income Tax relief, or SEIS Income Tax relief, (which have not been withdrawn) and other shares intermingling.