Readers’ forum: EISy does it

My client has substantial income from a foreign employment as well as substantial amounts of enterprise investment scheme (EIS) relief. In 2014/15 the figures on the tax calculation produced by HMRC’s system come – in round terms – to the following: total income £260 000; income tax charged £104 000; EIS relief £93 000; and double tax relief £51 000.

This leaves a tax liability of nil. The calculation shows the EIS relief coming off before the double tax relief. Because the client’s EIS investments often go bust my concern is that the income tax relief given on subscription will reduce an allowable loss on disposal. However has the income tax relief been given at £93 000 (and double taxation relief wasted) or has income tax relief been given at £53 000 (and double taxation relief allowed in full)?

The order of the...