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HMRC internal manual

Venture Capital Schemes Manual

EIS: deferral relief: shares issued on or after 6 April 1998: when is deferred gain brought back into charge: tranche size exceeded


The tranche size for an investee company may be exceeded in respect of an issue of shares on which EIS deferral relief has been claimed as a result of an event occurring after the claim has been made- see VCM12055. As a result any shares which form part of an issue which exceeds the tranche size will cease to qualify and the deferred gain is brought back into charge.

The deferred gain will be brought back into charge on the date of the relevant event, which will usually be the date of submission of the compliance certificate that caused the tranche size to be exceeded.