Income Tax Act 2007 Schedule 2 paragraph 45

The gross assets requirement

Schedule 2 paragraph 45 modifies the gross assets requirement under section 142 for shares issued before 6 April 2006, and disapplies it entirely for shares issued before 6 April 1998.

• For shares issued before 6 April 2006, the gross assets limits in section 142 are increased: £7 million becomes £15 million, and £8 million becomes £16 million
• Shares issued on or after 6 April 2006 are treated as issued before that date if the subscriber committed to them before 22 March 2006
• The gross assets requirement under section 142 does not apply at all to shares issued before 6 April 1998
• The effect is that earlier share issues are subject to more generous gross assets thresholds, or no threshold at all, reflecting the rules in force at the time of issue