Income Tax Act 2007 section 257QI

Section 257QH: supplementary

Section 257QI sets out supplementary rules governing when replacement value can (and cannot) be used to prevent the withdrawal or reduction of Social Investment (SI) tax relief, and restricts relief where the replacement value arises from a new investment by the investor or an associate.

  • Replacement value that has already been matched against a receipt of value to preserve SI relief cannot be used again for the same purpose
  • Replacement value is disregarded if it is provided outside the permitted time limits — broadly, it must fall within the longer applicable period and be provided as soon as reasonably practicable after the original value was received, or within 60 days of the final determination of any appeal
  • Where the replacement value qualifies and causes receipts of value to be ignored, but the event giving rise to it involves a new investment by the investor or an associate, no SI relief is available on that new investment or any other investments in the same issue
  • The replacement value does not have to be received after the original value — it can be provided beforehand and still qualify

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