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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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VCT: VCT qualifying holdings: UK permanent establishment requirement


This legislation applies in respect of shares or securities issued on or after 6 April 2011 and replaces the previous requirement that the relevant company carry on the qualifying trade wholly or mainly in the UK. It was introduced as part of the conditions under which the schemes were granted State aid approval by the European Commission.

The requirement is that the relevant company must have a permanent establishment in the United Kingdom at any time on or after the issue of the relevant holdings.

The legislation does not stipulate where the monies raised under the scheme are to be used. For the meaning of ‘permanent establishment’ see VCM55040.