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HMRC internal manual

Venture Capital Schemes Manual

VCT: investor CG deferral relief: to whom does the chargeable gain accrue?


Paragraph 5 gives the rules for determining the person to whom the deferred gain accrues if there is a chargeable event. These rules are necessary because the original investor may have passed the shares to their spouse or civil partner on a transfer to which TCGA92/S58 applied. If there is a chargeable event the gain is assessable on:

  • the person making the disposal,
  • the person who holds the shares at the time of the share exchange or company reconstruction or amalgamation,
  • the person who becomes non-resident,
  • the person who holds the shares when the company’s VCT approval is withdrawn,
  • the person who holds the shares when the ‘front-end’ income tax relief is withdrawn or reduced.