Income Tax Act 2007 section 257QL

Amount of repayments etc if there is more than one issue of shares

Section 257QL explains how to apportion a repayment of share capital across multiple share issues when calculating the withdrawal or reduction of Social Investment (SI) tax relief.

  • This section applies where a single repayment triggers withdrawal of SI relief attributable to two or more separate issues of shares
  • The repayment amount (referred to as "A" in section 257QJ) must be apportioned between the different share issues using the fraction I / T
  • "I" represents the amount on which SI relief was obtained by individuals for shares in a particular issue, and "T" is the total of all such amounts across all relevant issues
  • The effect is that each share issue only bears its fair share of the repayment, proportionate to the SI relief obtained on that issue relative to the total relief across all issues

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