VCM23040 | EIS: deferral relief: shares issued on or after 6 April 1998: qualifying investors
From HM Revenue & Customs · Venture Capital Schemes Manual
TCGA92/SCH5B/PARA1 (1)(a), (1)(d) & (4)
To qualify for relief, the investor must be an individual (or the trustees of a qualifying settlement, see VCM23510) who is resident or ordinarily resident in the UK both at the time the gain accrued and at the time the shares are issued. No claim to relief is allowed if the investor:
is also treated as resident in another country by virtue of double taxation relief arrangements, and
would not be liable to CGT if the EIS shares were sold at a gain immediately after they were issued.