Eligible Shares
27/03/1986
Query
Whether relief is transferable in the case of a married couple jointly assessed for tax.
Decision
No. The maximum allowable subscription of £25,000 applies to each spouse seperately.
Income Tax
Section 490, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:4297/86
12/07/1988
Query
Whether relief should be allowed for part shares if and when bonus share issue takes place that will eliminate any part shares being held by investors.
Decision
Relief allowed as the bonus issue would ensure that each investor would be registered as the owner of full shares.
Income Tax
Section 489, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:2476/87
28/07/1994
Query
When did shares actually issue? Would Revenue accept that the share "issued" when a mutual obligation arose whereby the applicant was obliged to take the shares and the company was obliged to cause those shares to be registered in the applicants name?
Decision
The issue of shares occurred when the legal title was completed by way of registration. BES and share capital relief can be claimed only when the applicants have been issued with the relevant share certificates.
Income Tax
Section 489, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:2014/93