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HMRC internal manual

Venture Capital Schemes Manual

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


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.