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HMRC internal manual

Venture Capital Schemes Manual

HM Revenue & Customs
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CVS: general: the shares


The shares in respect of which reliefs under the CVS are to be obtained must satisfy the following conditions:

  • they must be ordinary shares,
  • throughout the qualification period (see VCM90170 onwards) they must carry no preferential right to dividends or to the company’s assets in a winding up, and no present or future right to be redeemed,
  • the subscription for the shares must consist wholly of cash,
  • the shares must be fully paid up at the time of issue.
  • they must have been issued on or before 31 March 2010

As regards the last condition, shares are not to be regarded as fully paid up unless the whole of the subscription price has actually been paid. This contrasts with the position under company law, which treats an undertaking to pay at a future date as equivalent to payment.