Taxation of Chargeable Gains Act 1992 Schedule 5BB paragraph 4

Attribution of SEIS re-investment relief to relevant SEIS shares

Section 4 of Schedule 5BB sets out how the amount of SEIS re-investment relief is spread equally across the qualifying shares, and how that attribution is adjusted when bonus shares are issued.

• The total SEIS expenditure set off against a chargeable gain is divided proportionately across all relevant SEIS shares in respect of which the relief claim is made.
• This attribution applies whether the whole or only part of the SEIS expenditure is used to offset the gain.
• If bonus shares are later issued in respect of some or all of the original SEIS shares, the relief previously attributed to those original shares is re-spread proportionately across the combined holding of original and bonus shares.
• This mechanism ensures the correct amount of relief can be recovered on a per-share basis if a later clawback arises under paragraph 5 or 6 of Schedule 5BB.