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HMRC internal manual

Venture Capital Schemes Manual

EIS: deferral relief: shares issued on or after 6 April 1998: value received by investor


If an investor subscribes for shares that are eligible for deferral relief but receives value from the company within a certain period, see VCM23310, the shares are treated as:

  • never having been eligible shares if the value was received on or before the date of issue of the shares, or
  • ceasing to be eligible shares if the value was received after that date.

Note that the amount of the gain assessable is the whole amount. There is no apportionment of the gain brought back into charge even if only part of the value of the investment is returned. Where the investor is a trustee see also VCM23540.

There are two situations when value received on or after 7 March 2001 may be disregarded:

  • when the value received is insignificant, see VCM23380,
  • when the original supplier of value receives replacement value, see VCM23400.