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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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EIS: disposal relief: rights issues

TCGA92/S150A (7)

The share reorganisation rules on rights issues are disapplied if the original shares attracted EIS Income Tax relief or if the new shares attract the relief and the original shares did not. The taxpayer is treated as having acquired the new shares at the date of the rights issue and for the amount paid for the new shares. Any shares acquired on a rights issue may qualify for EIS Income Tax relief and deferral relief.