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HMRC internal manual

Venture Capital Schemes Manual

EIS: deferral relief: shares issued before 6 April 1998: same day acquisitions: disposals before 6 April 1998

The same day rule will usually apply where an investor has made a single subscription and claimed deferral relief on some but not all of the shares. To apply the same day rule you have to identify the shares which have attracted deferral relief. The basic steps are as follows:

  • Identify the amount in respect of which Income Tax relief under ICTA88/S289A was given. This will be £100,000 or the amount of the subscription whichever is lower.
  • This amount is attributed equally to each share subscribed for.
  • Calculate the number of shares required to give effect to the deferral relief claim.

These steps are illustrated in the examples in VCM22140.