Income Tax Act 2007 section 221

Receipts of value by and from connected persons etc.

Section 221 broadens the definitions used in the "value received" rules (sections 213, 214 and 216 to 218) so that EIS relief cannot be preserved by routing benefits through connected persons or associates rather than directly between the investor and the issuing company.

• Any reference to a payment or transfer to the investor covers payments made indirectly, to the investor's order, or for the investor's benefit
• Any reference to the investor also includes an associate of the investor
• Any reference to the issuing company extends to any person connected with that company at any time during period A for the relevant shares, even if the connection does not exist at the particular time the value is received
• Without these extended definitions, the rules on withdrawal or reduction of EIS relief could be circumvented by channelling value through intermediaries or connected parties