VCM68030 - VCT: deferral relief: which investments qualify?
TCGA92/SCH5C/PARA1 (2)
To qualify for deferral relief the taxpayer must receive
‘front-end' Income Tax relief on the subscription, see
VCM64020 onwards. The maximum amount of
deferral relief which can be claimed in any one tax year is the
total amount subscribed up to £100,000 for shares issued in
that one tax year. But a gain of more than £100,000 can be
deferred by subscriptions for shares issued in different tax years.
An investor who is unable to obtain the full amount of
'front-end' Income Tax relief available because his or her Income
Tax liability is insufficient can still claim deferral relief on
the full amount which would qualify for 'front-end' Income Tax
relief. For example an investor subscribes £100,000 for
100,000 VCT shares which are issued in the same tax year as the
subscription is made. Because his or her Income Tax liability is
insufficient the investor's 'front-end' Income Tax relief is
restricted to £12,000 but he or she can claim deferral relief
up to the full subscription of £100,000 for shares issued in
that tax year.
Deferral relief is not available if the investor's Income Tax
liability is nil before taking account of ‘front-end' Income
Tax relief. In these circumstances no ‘front-end' Income Tax
relief is actually given and as a result deferral relief is not
available.
VCT deferral relief is abolished for shares issued after 5
April 2004.
