Commentary

D8.355 Value received by persons other than the investing company

Corporate tax
Corporate tax | Commentary

D8.355 Value received by persons other than the investing company

Corporate tax | Commentary

D8.355 Value received by persons other than the investing company

Investment relief is reduced (or ultimately withdrawn)1 if, during the restriction period2, the issuing company or its subsidiary (as defined below) repays, redeems or repurchases any of its share capital other than that owned by:

  1.  

    (a)     an investing company under the corporate venturing scheme when the transaction would cause the reduction or withdrawal of investment relief because of a disposal of shares3 or a receipt of value as a result of repayment of share capital4; or

  2.  

    (b)     investors under the enterprise investment scheme (EIS) when the transaction would cause the reduction (or withdrawal) of EIS investment relief because of a disposal of shares5 or a receipt of value as a result of repayment of share capital6, or would cause a gain that was postponed under the EIS deferral relief to be brought into charge7.

(For both shares issued after 6 March 2001 and repayments received after that date for shares that were already in issue, investment relief is also reduced (or ultimately withdrawn) if the transaction would have fallen within (a) or (b) above were it not a receipt of insignificant value8.)

The relief is also reduced (or ultimately withdrawn) if the issuing company

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