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HMRC internal manual

Venture Capital Schemes Manual

From
HM Revenue & Customs
Updated
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SEIS: income tax relief: the investor: no related investment arrangements

ITA07/S257BC

An investor will not qualify for SEIS relief if he has subscribed for the shares as part of a reciprocal arrangement which involves somebody else subscribing for shares in a company in which the investor has a substantial interest in return for the investor subscribing in a company in which the other person has a substantial interest. The legislation is drafted in such a way as to disqualify shares issued under arrangements involving multiple investors and multiple companies. (See VCM32030 for meaning of ‘substantial interest’.)