Double-dipping pension and VCT tax reliefs

[Womble7]

Is it permissible to "double dip" pension and VCT tax reliefs ?

I have self-employed earnings of £40k (after expenses; I am a sole trader). Because I have sufficient other savings I put all my earnings into a personal pension (£32k contribution which is then grossed up to £40k by my personal pension provider). I benefit from £8k tax relief ('relief at source') within the pension but I still owe BRT @ 20% through my tax return. My tax liability is 20% of £27,500 (£40k - personal allowance of £12,500) = £5,500.

However, can I offset that £5,500 by investing in a VCT? With VCT income tax relief of 30%, investing £18,333 (of my savings) in a VCT would wipe out that £5,500 liability.

Would HMRC have a problem with this "double dipping", as I am effectively already getting tax relief on the £5,500 income tax liability within my pension?

Answers/relevant rules or legislation much appreciated....

[iwmtaxadvisor]

No problem.
I did hunt around for the order of reliefs for half an hour or so, eventually coming to the conclusion that if there was a liability for tax left over there was no reason why a VCT claim could not reduce that, subject to the claim being the same or less than the tax liability.
Then I found this useful comment from HMRC which agrees:-
https://community.hmrc.gov.uk/forums/customerforums/pt/37f4d401-2c4c-ea11-b698-00155d9c7b1d
VCTs have large annual charges, so whether this would leave you better off compared to another investment or tax favoured investment over say 10 years is a separate and probably required computation.

[Womble7]

Thanks for the reply. That said, not sure the HMRC comment is that clear!

But, essentially, you're saying the fact that the earnings are already getting BRT relief through the pension doesn't preclude also being able to mop up the BRT liability by using another tax relief (VCT in my case)? ie. the combination will not be seen as an abuse by HMRC?

And presumably this only works with a personal pension but not with an occupational pension where contributions are gross and there is no tax to pay?