Income Tax Act 2007 section 257HC

Carry over of obligations etc where SEIS relief attributed to new shares

Section 257HC ensures that when SEIS relief is transferred from old shares to new shares following a company acquisition, all existing obligations, actions, and rights transfer from the old company to the new company.

• When SEIS relief moves from old shares to new shares under a company takeover, this section transfers all related obligations to the new company
• Anything already done or required to be done by the old company regarding claims for relief, correction of relief found not to be due, or providing information to HMRC is treated as having been done or required by the new company instead
• The new company inherits responsibility for ongoing compliance obligations, including information reporting duties that previously fell on the old company
• Any appeal the old company has already lodged against an HMRC notice that relief was not due can be continued by the new company as though it had brought the appeal itself