E3.245 Investments made by the VCT must be qualifying holdings
The VCT provisions1 define which investments made by the VCT in a small company qualify as a qualifying holding of the VCT and thereby attract the associated tax reliefs. These are similar to the EIS provisions for qualifying companies (see E3.126), although one of the main differences is that under the EIS the investment must be in equity capital, whereas the investment by a VCT can also consist of securities.
For the purposes of these provisions, a security in relation to a company is required to have a degree of permanence.
Loans made on or after 15 March 2018
For these purposes, a loan is made on the day on which the amount lent, or (as the case may be) the first day on which any part of the amount lent, is paid or made available to the company. For loans made on or after 15 March 2018, the definition of securities2:
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