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HMRC internal manual

Venture Capital Schemes Manual

VCT: investor CG deferral relief: individual becomes non-resident

The deferred gain will not be brought back into charge by TCGA92/SCH5C/PARA3(1)(d) or (e) if someone emigrates by reason of their employment and all the conditions below are satisfied:

  • They become non-resident because they are working in an office or employment all the duties of which are performed outside the UK.
  • They become resident or ordinarily resident again within 3 years of the date of emigration.
  • During their absence they do not dispose of any of the VCT shares on which they have claimed deferral relief.

If the first condition is satisfied HMRC officers must wait until the end of the 3 year period to see if the other conditions are satisfied before assessing the deferred gain.