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HMRC internal manual

Venture Capital Schemes Manual

VCT: investor income tax reliefs: ‘front-end’ income tax relief: when relief is not due

ITA07/S261(3) & S264

Relief is not due:

  • if the shares were acquired as part of a tax avoidance scheme, or
  • if a loan was made which would not have been made, or would not have been made on the same terms, if the shares had not been subscribed for - see SP6/98 (reproduced at VCM11030).