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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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EIS: deferral relief: shares issued on or after 6 April 1998: qualifying investors

TCGA92/SCH5B/PARA1 (1)(a), (1)(d) & (4)

To qualify for relief, the investor must be an individual (or the trustees of a qualifying settlement, see VCM23510) who is resident or ordinarily resident in the UK both at the time the gain accrued and at the time the shares are issued. No claim to relief is allowed if the investor:

  • is also treated as resident in another country by virtue of double taxation relief arrangements, and
  • would not be liable to CGT if the EIS shares were sold at a gain immediately after they were issued.