VCM53040 | VCT: investor CG deferral relief: which individuals qualify?
From HM Revenue & Customs · Venture Capital Schemes Manual
TCGA92/SCH5C/PARA1 (4)
To qualify for relief the investor must be resident or ordinarily resident in the UK at the date the gain accrued and on the date they subscribed for the shares. They could not claim relief if:
they were also treated as resident in another country by virtue of double taxation relief arrangements, and
they would not be liable to CGT if the VCT shares were immediately sold at a gain (ignoring for this purpose CGT disposal relief for VCT shares).