Income Tax Act 2007 section 257FJ

Value received where there is more than one issue

Section 257FJ deals with how value received by an investor is apportioned when the investor has obtained SEIS relief on more than one share issue from the same company.

• Where an investor holds SEIS-relieved shares from two or more issues by the same company and receives value during the applicable periods for more than one of those issues, the value must be split between the issues rather than applied in full against each one.
• The value (referred to as "R" in section 257FE(2)) is reduced for each issue by multiplying it by a fraction: the amount on which SEIS relief was obtained for that particular issue divided by the total amount on which SEIS relief was obtained across all the relevant issues.
• This apportionment ensures the investor is not penalised multiple times for the same receipt of value — instead, the impact is spread proportionally according to the size of each SEIS investment.
• The "applicable period" for any issue of shares means period A in relation to those shares, which is the period during which value received can trigger a withdrawal or reduction of SEIS relief.