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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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VCT: VCT approval: nature of the income condition

ITA07/S274(2) and S276

A VCT’s income must derive wholly or mainly from shares or securities during the relevant period. HMRC will regard a VCT’s income as being derived wholly or mainly from shares or securities where at least 70% of its income is derived from these sources.

The amounts of income to be brought into account in respect of any loan relationships covered by Part 5 of CTA 2009 should be calculated without reference to any of the company’s debtor relationships. The excess of non-trading loan relationship credits over non-trading loan relationship debits is then to be treated as income of the VCT deriving from shares and securities. For more information on loan relationships, seeCFM30000.