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HMRC internal manual

Venture Capital Schemes Manual

From
HM Revenue & Customs
Updated
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CVS: investors and reliefs: purpose of making the investment

FA00/SCH15/PARA14

The company must subscribe for the shares for commercial reasons. The subscription must not be part of a scheme or arrangement one of whose main purposes is the avoidance of tax. Before any case is challenged on either of these grounds a report should be made to CTIAA (Structure, Incentives & Reliefs team).