Income Tax Act 2007 section 227

Single issue affecting more than one individual

Section 227 deals with how to apportion a repayment of share capital for EIS relief withdrawal purposes when the same share issue has EIS relief attributable to shares held by two or more individuals.

• This section applies when a single repayment of share capital triggers a potential withdrawal of EIS relief for two or more individual shareholders under the same share issue.
• Each individual's share of the repayment amount ("R") is reduced by multiplying it by the fraction A/B, where A is that individual's EIS relief amount and B is the total EIS relief obtained by all affected individuals.
• The calculation takes account of cases where an individual has claimed EIS relief on only some of the shares they were eligible for, using the amount on which relief was actually obtained.
• The effect is that the repayment is split fairly among the affected individuals in proportion to the EIS relief each has claimed on the relevant shares.