VCM23540 - EIS: deferral relief: shares issued on or after 6 April 1998: trustees: anti-avoidance

TCGA92/SCH5B/PARA18

TCGA92/SCH5B/PARA13 and PARA15, see VCM23300 onwards and VCM23470, apply where the investor is a trustee as if references to the investor included:

• the trustees themselves,
• any beneficiary (individual or charity) who has an interest in the property at a relevant time which qualifies for deferral relief, see VCM23510,
• any associate, see VCM23370, of such an individual, or any person connected with such a charity.

Meaning of relevant time

For the purposes of TCGA92/SCH5B/PARA18 the relevant times are the date the shares are issued, and

• the time when the value is received, even if its effect is disregarded because it is an amount of insignificant value, see VCM23300 onwards, or
• in a case where the effect of a receipt of value is disregarded because of a receipt of replacement value, see VCM23400 onwards, the time when the original value is received, or
• the time when the loan is made, see VCM23470.