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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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EIS: deferral relief: shares issued before 6 April 1998: when is the deferred gain brought back into charge: death


Death is not treated as a disposal. Therefore the death of an investor does not give rise to a release of the deferred gain. Neither will the deferred gain be released if any of the events listed in VCM22070 occur after the date of death. The same rule applies to the death of any person who acquires the shares on a no gain/no loss transfer.