Income Tax Act 2007 section 257HI

Meaning of "issue of shares"

Section 257HI defines what is meant by an "issue of shares" for the purposes of the Seed Enterprise Investment Scheme (SEIS).

• An "issue of shares" in a company means all shares of the same class issued on the same day.
• An "issue of shares" to an individual means all shares of the same class issued to that person in one capacity on the same day.
• Where an individual holds shares in more than one capacity (for example, personally and as a trustee), each capacity is treated as a separate issue.
• The definition of an issue to an individual is subject to certain overriding provisions dealing with attribution of relief, timing of claims, cases where maximum relief is not obtained, and value received in respect of shares treated as issued in a previous tax year.