Income Tax Act 2007 section 257HD

Substitution of new shares for old shares

Section 257HD ensures that when old SEIS shares are exchanged for new shares following a company takeover, the new shares inherit the same SEIS history and tax treatment as the original shares.

• New shares are treated as having been subscribed for at the same time and for the same amount as the original old shares
• New shares are treated as having been issued at the same time the old shares were originally issued
• Any SEIS relief claim made for the old shares is treated as having been made for the new shares
• The income tax reduction for the new shares applies to the same tax year as the reduction originally given for the old shares