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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: who is assessable?


Rules are necessary to determine on whom the deferred gain should be assessed when there is a chargeable event. These rules are necessary because the original investor may have passed the shares on to their spouse or civil partner on a transfer to which TCGA92/S58 applies. If there is a chargeable event the gain is assessable on:

  • the person making the disposal,
  • the person who becomes non-resident,
  • the person who holds the shares when they cease to be eligible.