Special Portfolio Investment Accounts (SPIA)
15/07/1997
Query
If a SPIA holder gets income from the SPIA in the form of shares, can the shares be left in the SPIA without breaching the investment limit.
Decision
Yes, provided the income is not taken out of the SPIA. The investment limit is breached only if the cash given to the designated broker for investment exceeds the limit. After 5 years the balance in the SPIA must be reduced to the prescribed limit.
Income Tax
Section 838, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:GD93011
04/12/1997
Query
Whether the 10% limit for special qualifying share applies only at the date of the original investment.
Decision
The aggregate of the consieration given for shares which are AT ANY TIME held in a SPIA must be, as respects specified qualifying shares, at least 10% of the aggregate of the consideration given for the assests of the SPIA AT THAT TIME.
Income Tax
Section 838, Taxes Consolidation Act, 1997
Origin: RLS Division
File ref:GD93011A