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HMRC internal manual

Venture Capital Schemes Manual

VCT: VCT qualifying holdings: requests for advance assurance: dealing with applications

Although the advance assurance service is not statutory, HMRC is normally bound by any assurance given where the information supplied was correct and complete at the time and has not been superseded by subsequent events. In order to avoid any misunderstanding it is important that all information provided is given in writing.

For the same reason, it is also important that requests are considered very carefully. Both the information supplied and information available on the tax files of the investee company and any subsidiaries, should be taken into account before any decision is made. Companies seeking an assurance therefore need to allow adequate time for HMRC to consider the request properly. VCT investments are generally more complicated than those for other schemes and advance assurances may take longer than others to review.

Any assurance supplied to a company is given only on the basis of the information provided. HMRC is under no obligation to check the accuracy or completeness of that information. However, it is important that any obvious gaps in the information should be filled and any apparent contradictions explained. An officer may ask further questions to ensure that that is the case, or decline to provide an opinion if the information supplied is not sufficient to form an opinion.