Income Tax Act 2007 section 219

Value received where part of share issue treated as made in previous tax year

Section 219 deals with how to calculate the reduction in EIS relief when an investor receives value from the company, and part of the share issue is treated as having been made in a previous tax year.

• This section applies where the investor has received value from the company (under section 213(2)) and part of the share issue is treated as having been issued in the previous tax year for EIS relief purposes.
• The amount of value received ("R") must be split between the two tax years in proportion to the amount of EIS relief obtained in each year.
• For each year's apportioned amount, a separate calculation is performed as if there were two distinct share issues, applying section 220 where appropriate but not section 218.
• The results of the two separate calculations are added together to produce the final amount by which EIS relief is reduced.