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HMRC internal manual

Venture Capital Schemes Manual

From
HM Revenue & Customs
Updated
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CVS: general: purpose of issuing shares has to be commercial

FA00/SCH15/PARA38

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).