CG63610 - Investors바카라 사이트� Relief: Joint Holdings
TCGA92/S169VJ
S169VJ ensures that where a qualifying person disposes of an interest in a relevant holding Investors바카라 사이트� Relief is potentially available where the subscription was made jointly with one or more other individuals.
Where a share is jointly owned then each person will own an interest in that share. S169VJ allows Investors바카라 사이트� Relief to apply when shares are held jointly so that the disposal by an individual investor is of their 바카라 사이트榠nterest바카라 사이트� in the shares.
Example
Francis, Kim, Joey and David are friends who pool money to make small investments in unquoted companies. They don바카라 사이트檛 always agree so not all of them may choose to invest in a particular company at a particular time. Assume all other conditions for Investors바카라 사이트� Relief are met.
The following share subscriptions are made in P Ltd -
June 2016 바카라 사이트� they all agree it looks a good prospect so subscribe for 500 shares between the four of them.
January 2017 바카라 사이트� Francis, Kim and Joey subscribe for another 350 shares together; however David preferred to invest in a higher risk company.
August 2017 바카라 사이트� Francis received a small inheritance and used some of it to buy 500 P Ltd shares.
September 2017 바카라 사이트� P Ltd makes a rights issue, this time only Francis and Joey feel it is a good investment and jointly buy 150 shares.
Looking at Francis바카라 사이트檚 holding, he has sole ownership of 500 shares and an interest in another 1000. The proportionate interest in shares varies.
For Investors바카라 사이트� Relief purposes Francis has the following holding바카라 사이트�
Initial holding at June 2016 (500/4) 125
Add January 2017 (350/3) 117 (rounded)
Add August 2017 500
Add September 2017 (150/2) 75
Holding at September 2017 817
Partnerships and LLPs
Where a partnership (or an LLP, which is normally treated for tax purposes as a partnership) subscribes for shares, the individual partners are treated as having themselves subscribed (section 59(1)(b)). It is not necessary for the partners to have directly funded the subscription: the new consideration given for the shares may have come out of partnership funds. In cases of 바카라 사이트減artnership subscriptions바카라 사이트�, therefore, each partner is deemed to have subscribed for a fraction of the total shares issued. The fraction is to be the same as the partner바카라 사이트檚 fractional share in the assets of the partnership at the time the shares are issued.
By way of example, if a partnership of four individuals with asset shares in the ratio 40:30:20:10 subscribes for 1000 shares, the partners are treated as having subscribed for 400, 300, 200 and 100 shares respectively.
If a new partner is admitted and each existing partner transfers 10% of their asset-share to the new member then they are treated as disposing of (40+30+20+10) shares eligible for Investors바카라 사이트� Relief. The new member will not be able to claim Investors바카라 사이트� Relief on the 100 shares as she is treated as acquiring the shares as she did not subscribe for them.
See CG63500 for a general description of the relief and the layout of the guidance.