Income Tax Act 2007 section 257E

Attribution of SEIS relief to shares

Section 257E sets out the rules for how SEIS income tax relief obtained by an individual is attributed to the specific shares (or issues of shares) that gave rise to that relief.

• Where a tax reduction arises from a single share issue, the relief is attributed to that issue; where it arises from multiple issues, the relief is apportioned between them in proportion to the amounts claimed for each issue, and then divided equally among the individual shares within each issue.
• If corresponding bonus shares (same company, same class, same rights) are issued in respect of shares already carrying SEIS relief, the total relief previously attributed to the original shares is spread proportionately across the combined holding of original and bonus shares, and the bonus shares are treated as part of the original issue.
• Where part of a share issue is treated under section 257AB as having been issued in a previous tax year, that part and the remainder are regarded as separate issues for attribution purposes.
• If SEIS relief is later withdrawn or reduced under Chapters 6 and 7, the relief attributed to each affected share is either reduced to nil (on full withdrawal) or reduced by a proportionate part of the reduction amount.