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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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EIS: taper relief for serial investments: business or non-business asset: Taper relief does not apply to gains accruing or treated as accruing after 5 April 2008


There are special rules to determine how much of the revived gain qualifies for the business asset taper and how much qualifies for the non-business asset taper.

First, trace the path of successive holdings of shares which begins with the investment in the first company and ends with the investment whose disposal finally revives the gain.

Second, treat the revived gain as though it were a gain on the disposal of an asset which in turn assumes the character of each shareholding in the path for the period in which the shares in question were held.

If there is a period in which two successive shareholdings are held simultaneously, the character of the one acquired earlier is assumed until it is disposed of, at which point the character of the later acquisition is assumed instead, see example at VCM25100.