Income Tax Act 2007 section 231

Restriction on withdrawal of relief under section 224

Section 231 limits the impact of section 224 (which deals with repayments of share capital to other persons) where a repayment has already triggered a withdrawal or reduction of corporate venturing scheme investment relief under Schedule 15 to the Finance Act 2000.

  • Where a repayment causes investment relief under the corporate venturing scheme to be withdrawn, a "relevant amount" is calculated as the repayment minus five times the investment relief withdrawn (A − 5B)
  • If the relevant amount is £1,000 or less, the repayment is ignored for EIS relief withdrawal purposes under section 224, unless pre-arranged repayment plans existed in the 12 months before the share issue date up to and including that date
  • If the repayment cannot be ignored, the amount treated as received for section 224 purposes is reduced to the relevant amount rather than the full repayment figure
  • Repayment arrangements include any plans for repayment by the issuing company or any of its subsidiaries (including companies that became subsidiaries after the arrangements were made)

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