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HMRC internal manual

Venture Capital Schemes Manual

VCM22050 - EIS: deferral relief: shares issued before 6 April 1998: which individuals qualify?

TCGA92/SCH5B/PARA1 (4)

To qualify for relief the investor must be resident or ordinarily resident at the date the gain accrued and the date on which they subscribed for the shares. They cannot claim relief if:

  • they are also treated as resident in another country by virtue of double taxation relief arrangements, and
  • they would not be liable to CGT if the EIS shares were sold at a gain immediately after they were issued.