HMRC are publishing revised advance assurance guidance for the Venture Capital Schemes. The guidance will be contained in VCM60000+ and introduces a Checklist which must be completed and submitted alongside any advance assurance requests to the Venture Capital Reliefs Team.
It seems the purpose of the new checklist is to signpost HMRC to the relevant technical points in an application, given the large volume of information now required to be sent to HMRC with an advance assurance application. HMRC have stated that a Company ‘must draw attention in its application to each point of doubt with a full technical explanation as to why it believes the requirement is met’. Further, ‘The checklist enables the company to explain to HMRC where all the relevant information and supporting evidence can be found, and to highlight areas of doubt. The relevant information must be fully signposted in the checklist; in order to manage demand for the advance assurance service, the Venture Capital Reliefs Team officer will not spend time identifying relevant information from the documents provided.’
HMRC have also revised guidance in VCM14000+ and VCM35000+, taking out all the chapters relating to advance assurance guidance.
Whilst the advance assurance service is highly valued for the majority of SEIS and EIS investors, most VCT investments are now made without seeking advance assurance in accordance with HMRC’s preference as stated at VCM 55360.