Commentary

D8.333 Qualifying investments—issuing arrangements

Corporate tax
Corporate tax | Commentary

D8.333 Qualifying investments—issuing arrangements

Corporate tax | Commentary

D8.333 Qualifying investments—issuing arrangements

The issuing arrangements for the relevant shares must not include certain features which, broadly, provide for a means of realising the investment or reduce the risk associated with making the investment. There are four requirements—

First, the issuing arrangements must not provide for subsequent repurchase, exchange or other disposal of the investment shares or any other shares or securities of the issuing company1. This does not include certain exchanges when a new company acquires the shares within FA 2000, Sch 15, para 83(1) (concerning certain arrangements resulting in the acquisition of share capital by a new company)

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