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HMRC internal manual

Venture Capital Schemes Manual

CVS: general: purpose of issuing shares has to be commercial


The investing company is not eligible for investment relief if the shares are not issued for commercial purposes, or are issued as part of a scheme or arrangement whose main purpose, or one of whose main purposes, is the avoidance of tax. Before any case is challenged solely on these grounds a report should be made to CTIAA (CT Structure, Incentives & Reliefs team).