188体育

TCGA92/SCH5C/PARA1 (2)

To qualify for deferral relief the taxpayer must have received 鈥榝ront-end鈥� income tax relief on the subscription, see VCM51020 onwards. The maximum amount of deferral relief which could be claimed in any one tax year was the total amount subscribed up to 拢100,000 for shares issued in that one tax year. But a gain of more than 拢100,000 could be deferred by subscriptions for shares issued in different tax years.

An investor who was unable to obtain the full amount of 鈥榝ront-end鈥� income tax relief available because his or her income tax liability was insufficient could still claim deferral relief on the full amount which would qualify for 鈥榝ront-end鈥� income tax relief. For example, an investor subscribes 拢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 was insufficient the investor鈥檚 鈥榝ront-end鈥� income tax relief is restricted to 拢12,000 but he or she could claim deferral relief up to the full subscription of 拢100,000 for shares issued in that tax year.

Deferral relief was not available if the investor鈥檚 income tax liability was nil before taking account of 鈥榝ront-end鈥� income tax relief. In these circumstances no 鈥榝ront-end鈥� income tax relief is actually given and as a result deferral relief is not available.