A family office is built on structure. Money moves through companies, partnerships and trusts because that is how a family keeps control, consolidates reporting and plans succession. The UK's venture capital reliefs point the other way. SEIS and EIS income tax relief is written for individual investors, and no entity, however the office is arranged, can claim it.
That one rule shapes everything else. Family members who subscribe personally can claim. An individual who subscribes through a nominee is treated as the subscriber. The office's own company, a family investment company included, cannot, and neither can the trustees of a standard trust. What remains is a genuine decision about where relief, control and risk should sit, and it deserves a clear look before anyone signs a subscription agreement.
The Carry's reading of HMRC's eligibility rules is unsparing: the schemes were built to put individuals' capital at risk, and no amount of family-office structuring changes who the relief can be paid to.
The relief follows the individual, never the structure that manages the money.
Can a family office claim SEIS or EIS relief as an entity?
No. SEIS and EIS income tax relief can only be claimed by individuals, a condition set out in GOV.UK's guidance on tax relief for investors and enforced in HMRC's Venture Capital Schemes Manual, which makes an individual subscriber a condition of eligibility (VCM10520). A company cannot claim the relief, and that includes a family investment company, however completely the family owns it. Trustee subscriptions do not qualify either, so a standard trust is out.
The legal wrapper of the office itself makes no difference. A single family office (an in-house team serving one family) might run as a limited company or a partnership; a multi-family office manages money for several families as a business. In every case the entity signs, holds and reports, and in every case the income tax relief passes it by. The schemes were designed to put private individuals' capital at risk in early-stage companies, and the eligibility rules hold that line.
Who in the family can claim the relief?
Individual family members who subscribe personally can claim, on the same terms as any other private investor. Under the current rules on GOV.UK, SEIS gives 50% income tax relief on up to £200,000 of subscriptions per tax year, and EIS gives 30% on up to £1m, rising to £2m where at least £1m goes into knowledge-intensive companies. Relief can be carried back to the previous tax year, and a claim can be made up to five years after the 31 January following the tax year of the investment.
Holding through a nominee does not break this. HMRC's manual treats an individual who subscribes via a nominee as the subscriber, so shares a nominee holds on a family member's behalf can still carry that member's relief, provided every other condition is met (HMRC VCM10520). What matters is who beneficially subscribes, not whose name sits on the register. One caution: family members who take a paid role or a board seat at the investee company run into a separate eligibility test, covered in the director and connection rules.
What conditions come with SEIS and EIS relief?
The shares must be full-risk ordinary shares, and both schemes require a minimum three-year hold, per GOV.UK. Those two conditions do most of the work in practice. Full-risk means no preferential rights that shelter the money, and the instrument a deal is written on can decide whether relief survives at all, a subject with its own traps, covered in which structures preserve the relief.
Just as important for a family office: every consequence of the investment sits with whoever holds the shares. If a family member has claimed relief, the three-year clock binds that member. Any loss on a failed company, and any capital gains treatment on a successful one, lands on the individual holder's tax position, not on the office's consolidated accounts. The relief and the risk travel together, and they travel to a person.
How does a family office weigh relief against control?
The trade is between tax relief that only individuals can keep and the consolidation that only the entity provides, and there is no single right answer. The factors below are the ones that move the decision. None of them is a recommendation.
- Where the relief lands. SEIS and EIS reduce an individual member's income tax bill, so the value depends on who in the family has UK income tax to relieve, and how much.
- What the entity offers instead. A company or trust brings consolidated reporting, governance and succession planning, and keeps the holding on one balance sheet. None of that attaches to a personal subscription, and no relief attaches to the entity.
- The hold and the risk. A personal claim ties that member to a three-year hold in a full-risk instrument, and the person on the share register carries the loss if the company fails.
- Family dynamics. A personal subscription is that member's asset, inside their estate, outside the office's control. For some families that is fine. For others it defeats the point of having an office at all.
Angels wrestle with a smaller version of the same question, and the mechanics are laid out in the personal versus limited-company trade-off. For a family office the stakes are larger and the answer is never generic: it turns on the family's tax positions, the office's purpose and the size of the cheques.
Where should a family office check the rules?
Start with the primary sources: GOV.UK's venture capital schemes guidance for the current rates, caps and conditions, and HMRC's Venture Capital Schemes Manual for the eligibility detail. Both change. Rates and limits have moved before and will move again.
Then treat the structuring question as what it is: regulated territory. Deciding who in a family should subscribe, through what arrangement, touching which reliefs, is tax planning and investment structuring, and both belong with professionals, an FCA-regulated adviser on the investment side and a tax adviser on the structuring side. This article is general information, not financial or tax advice, and nothing in it should be read as a route map for any particular family. The rules are the fixed part. How a family uses them depends entirely on circumstances this page cannot see.
Frequently asked questions
Can a family investment company claim EIS relief?
No. EIS income tax relief can only be claimed by individuals, and HMRC's Venture Capital Schemes Manual makes an individual subscriber a condition of eligibility. A family investment company is a company, so it cannot claim the relief, however the family holds its shares. Family members who subscribe for EIS shares personally can claim, subject to the scheme's other conditions.
Can family members claim SEIS or EIS on deals their family office finds?
Yes, provided they subscribe personally rather than through the office's entity and meet the scheme conditions: new full-risk ordinary shares, a minimum three-year hold, and the annual caps of £200,000 for SEIS relief at 50% and £1m for EIS relief at 30%, rising to £2m where at least £1m goes into knowledge-intensive companies. Connection rules can remove eligibility for members who take paid roles at the investee company.
Do shares held through a nominee still qualify for the relief?
They can. HMRC's Venture Capital Schemes Manual treats an individual who subscribes via a nominee as the subscriber, so relief can remain available to the family member the nominee holds for. Every other condition still has to be met, and the arrangement needs to be a genuine nominee holding for that individual.
Can a trust claim SEIS or EIS relief?
A standard trust cannot. Trustee subscriptions do not qualify for SEIS or EIS income tax relief, because the schemes restrict the income tax relief to individual investors. Moving shares into or out of trust structures can also disturb other conditions, which is one reason the structuring question belongs with a tax adviser.
Is this advice on how a family office should structure its investments?
No. This article is general information about the eligibility rules, not financial or tax advice. Deciding who in a family should subscribe, and through what arrangement, is regulated-advice territory. Check the current rules on GOV.UK and take advice from an FCA-regulated adviser and a tax adviser before committing capital.