Taxes Consolidation Act, 1997 (Number 39 of 1997)
[19]>
[12]>
489 The relief.
[FA84 s12(1), (3) to (6A), (8) and (10) to (11); FA85 s13(b); FA87 s8(b); FA90 s10(b) and s34(1)(a) and (b)(ii), (2) and (4); FA91 s15(1)(a); FA93 s25(b)(i), (iii), (iv), (v) and (vi); FA95 s17(b); FA96 s17]
(1) This Part shall apply for affording relief from income tax where, subject to subsection (2)—
(a) an individual who qualifies for the relief subscribes for eligible shares in a qualifying company,
(b) those shares are issued to the individual for the purpose of raising money for a qualifying trade being carried on by the company or which the company intends to carry on, and
(c) the company provides satisfactory evidence, and it appears to the Revenue Commissioners after such consultation, if any, as may seem to them to be necessary with such person or body of persons as in their opinion may be of assistance to them, that the money was used, is being used or is intended to be used—
(i) for the purposes of—
(I) enabling the company, or enlarging its capacity, to undertake qualifying trading operations,
(II) enabling the company to engage in, or assisting the company in—
(A) research and development,
(B) the acquisition of technological information and data,
(C) the development of new or existing products or services, or
(D) the provision of new products or services,
(III) enabling the company to identify new markets, and to develop new and existing markets, for its products and services, or
(IV) enabling the company to increase its sales of products or provision of services,
and
(ii) with a view to the creation or maintenance of employment—
(I) in the company, or
(II) in the case of qualifying trading operations referred to in section 496(2)(a)(ix), in either or both a company contracted to construct the advance factory building concerned and a company which enters into a lease for its use.
(2) Where the money raised for the purpose specified in subsection (1)(b) was used, is being used or is intended to be used—
(a) for the purposes of qualifying trading operations referred to in section 496(2)(a)(iv) and in respect of which money is raised or intended to be raised under this Part by virtue of section 496(2)(a)(iv)(II), the evidence referred to in subsection (1)(c) shall include the certificate referred to in section 496(5),
(b) for the purposes of qualifying trading operations referred to in section 496(2)(a)(vii), the evidence referred to in subsection (1)(c) shall include the certificate referred to in section 496(7),
(c) for the purposes of qualifying trading operations referred to in section 496(2)(a)(x) (in this paragraph referred to as “the operations”), the evidence referred to in subsection (1)(c) shall include a certificate by an industrial development agency certifying that it is satisfied that the operations—
(i) have the potential to result in the commencement of qualifying trading operations referred to in subparagraphs (i), (ii) and (viii) of section 496(2)(a), and
(ii) have commenced,
(d) for the purposes of qualifying trading operations referred to in section 496(2)(a)(xii), the evidence referred to in subsection (1)(c) shall include the certificate referred to in section 496(8),
(e) for the purpose of the construction and the leasing of an advance factory building, the evidence referred to in subsection (1)(c) shall include a certificate by an industrial development agency certifying that it has satisfied itself that—
(i) the building is or will be an advance factory building, and
(ii) (I) the advance factory building is or will be situated in an area which, on the basis of guidelines agreed with the consent of the Minister for Finance between the industrial development agency and the Minister for Enterprise, Trade and Employment or the Minister for Arts, Heritage, Gaeltacht and the Islands (as may be appropriate in the circumstances), was or is in particular need of development and of the creation of opportunities for employment, and
(II) the construction of the advance factory building contributes or will contribute significantly to meeting those needs, and
(f) for the purposes of relevant trading operations, the evidence referred to in subsection (1)(c) shall include a certificate under section 497(2).
(3) Subject to subsections (4) and (5), relief in respect of the amount subscribed by an individual for any eligible shares shall be given as a deduction of that amount from his or her total income for the year of assessment in which the shares are issued.
(4) Where—
(a) in accordance with section 508, relief is due in respect of an amount subscribed as nominee for a qualifying individual by the managers of a designated fund, and
(b) the eligible shares in respect of which the amount is subscribed are issued in the year of assessment following the year of assessment in which that amount was subscribed to the designated fund,
the individual may elect by notice in writing to the inspector to have the relief due given as a deduction from his or her total income for the year of assessment in which the amount was subscribed to the designated fund, instead of (as provided for in subsection (3)) as a deduction from his or her total income for the year of assessment in which the shares are issued.
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(4A) Notwithstanding any other provision of this section, where—
(a)(i) in accordance with section 508 relief is due in respect of an amount subscribed as nominee for a qualifying individual by the managers of a designated fund,
(ii) the amount so subscribed was subscribed to the designated fund in the period beginning on 1 January 2002 and ending on 31 January 2002, and
(iii) the eligible shares in respect of which the amount is subscribed by the managers of the designated fund are issued on or before 31 December 2002,
or
(b) eligible shares are issued by a qualifying company to a qualifying individual in the period beginning on 1 January 2002and ending on 31 January 2002,
the qualifying individual may elect by notice in writing to the inspector to have the relief due given as a deduction from his or her total income for the year of assessment 2001 instead of (as provided for in subsection (3)) as a deduction from his or her total income for the year of assessment 2002.
<[3]
[6]>
(4B) Notwithstanding any other provision of this section, where—
(a) (i) in accordance with section 508 relief is due in respect of an amount subscribed as nominee for a qualifying individual by the managers of a designated fund,
(ii) the amount so subscribed was subscribed to the designated fund in the period beginning on 1 January 2004 and ending on 4 February 2004, and
(iii) the eligible shares in respect of which the amount is subscribed by the managers of the designated fund are issued on or before 31 December 2004,
or
(b) eligible shares are issued by a qualifying company to a qualifying individual in the period beginning on 1 January 2004 and ending on 4 February 2004,
then the qualifying individual may elect, by notice in writing to the inspector, to have the relief due given as a deduction from his or her total income for the year of assessment 2003 instead of (as provided for in subsection (3)) as a deduction from his or her total income for the year of assessment 2004.
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[9]>
(4C) Notwithstanding any other provision of this section, where—
(a) (i) in accordance with section 508 relief is due in respect of an amount subscribed as nominee for a qualifying individual by the managers of a designated fund,
(ii) the amount so subscribed was subscribed to the designated fund in the period beginning on 1 January 2007 and ending on 31 January 2007, and
(iii) the eligible shares in respect of which the amount is subscribed by the managers of the designated fund are issued on or before 31 December 2007,
or
(b) eligible shares are issued by a qualifying company to a qualifying individual in the period beginning on 1 January 2007 and ending on 31 January 2007,
then the qualifying individual may elect, by notice in writing to the inspector, to have the relief due given as a deduction from his or her total income for the year of assessment 2006 instead of (as provided for in subsection (3)) as a deduction from his or her total income for the year of assessment 2007 and, where an election is so made, the relief to be given for the year of assessment 2006 shall be in accordance with section 490(2) as it applied for that year.
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(5) (a) Subject to this subsection, a specified individual may, in relation to a relevant investment made by such individual (being that individual’s first such investment), elect by notice in writing to the inspector to have the relief due given as a deduction from such individual’s total income for any one of the [4]>5 years<[4][4]>6 years<[4] of assessment immediately before the year of assessment in which the eligible shares in respect of that investment are issued which such individual nominates for the purpose, instead of (as provided for in subsection (3)) as a deduction from the specified individual’s total income for the year of assessment in which the shares are issued, and accordingly, subject to section 490 and paragraphs (c) and (d), for the purpose of granting such relief (but for no other purpose of this Part) the shares shall be deemed to have been issued in the year of assessment so nominated.
(b) Where the specified individual makes a subsequent relevant investment (being that individual’s second such investment)—
(i) in the same company as such individual’s first such investment, and
(ii) within either the year of assessment following the end of the year of assessment in which such individual’s first such investment was made or the year of assessment subsequent to that year,
then, the specified individual may, in relation to such individual’s second such investment, elect by notice in writing to the inspector to have the relief due given as a deduction from such individual’s total income for any one of the [4]>5 years<[4][4]>6 years<[4] of assessment immediately before the year of assessment in which the eligible shares in respect of such individual’s first such investment were issued which such individual nominates for the purpose, instead of (as provided for in subsection (3)) as a deduction from such individual’s total income for the year of assessment in which the eligible shares in respect of such individual’s second such investment are issued, and accordingly, subject to section 490 and paragraphs (c) and (d), for the purpose of granting such relief (but for no other purpose of this Part) the shares issued in respect of the second such investment shall be deemed to have been issued in the year of assessment so nominated.
(c) Where any of the years of assessment following the year of assessment nominated under paragraph (a) or (b), as the case may be, precede the year of assessment in which the eligible shares in respect of the specified individual’s first relevant investment are in fact issued, subsections (3) to (5) of section 490 shall operate to give relief in such years of assessment as may be nominated by such individual for that purpose.
(d) To the extent that the amount of the relief which would be due in respect of the specified individual’s first relevant investment or second relevant investment, as the case may be, has not been given in accordance with paragraphs (a) to (c) it shall, subject to subsections (3) to (5) of section 490, be given for the year of assessment in which the eligible shares in respect of the first such investment or the second such investment, as the case may be, are in fact issued or, if appropriate, a subsequent year of assessment.
(e) This subsection shall apply in respect of not more than 2 relevant investments made by a specified individual on or after the 2nd day of June, 1995.
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(f) This subsection shall apply notwithstanding any limitation in section 865(4) on the time within which a claim for a repayment of tax is required to be made. Section 865(6) shall not prevent the Revenue Commissioners from repaying an amount of tax as a consequence of an election made under the provisions of paragraph (a) or (b) where the specified individual has made a timely claim for relief in accordance with section 503 and a valid claim for a repayment of tax within the meaning of section 865(1)(b).
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(6) References in this Part to the amount of the relief are references to the amount of the deduction given under subsection (3), (4) or (5) (as may be appropriate).
(7) (a) Subject to paragraphs (b) and (c), the relief shall be given on a claim and shall not be allowed—
(i) (I) in the case of a relevant investment, unless and until the company commences to carry on the relevant trading operations, and
(II) in any other case, unless and until the company has carried on the trade for 4 months, and
(ii) if the company is not carrying on that trade at the time when the shares are issued, unless the company—
(I) expends not less than 80 per cent of the money subscribed for the shares on research and development work which is connected with and undertaken with a view to the carrying on of the trade, and begins to carry on the trade within 3 years after that time,
or
(II) otherwise begins to carry on the trade within 2 years after that time.
(b) In the case of qualifying trading operations referred to in section 496(2)(a)(ix), for the purposes of paragraph (a), the trade shall be deemed to have commenced on the date on which the construction of the advance factory building commenced.
(c) In the case of qualifying trading operations referred to in section 496(2)(a)(x), for the purposes of paragraph (a), the trade shall be deemed to have commenced on the date on which the certificate referred to in subsection (2)(c) was issued.
(8) Subject to subsection (7)(a)(i), a claim for relief may be allowed at any time if the conditions for the relief are then satisfied.
(9) In the case of a claim allowed before the end of the relevant period, the relief shall be withdrawn if by reason of any subsequent event it appears that the claimant was not entitled to the relief allowed.
(10) In the case of a claim allowed before a specified individual commences a relevant employment with the company in which that individual has made a relevant investment (being that individual’s first such investment), the relief shall be withdrawn if the specified individual fails to commence such employment—
(a) within the year of assessment in which the investment is made, or
(b) if later, within 6 months of the date of—
(i) where the investment consists of the subscription of only one amount for eligible shares, that subscription, or
(ii) where the investment consists of the subscription of more than one amount for eligible shares, the last such subscription.
(11) Where by reason of its being wound up, or dissolved without winding up, the company carries on the qualifying trade for a period shorter than 4 months, subsection (7)(a)(i) shall apply as if it referred to that shorter period but only if it is shown that the winding up or dissolution was for bona fide commercial reasons and not as part of a scheme or arrangement the main purpose or one of the main purposes of which was the avoidance of tax.
(12) Subject to section 506, no account shall be taken of the relief, in so far as it is not withdrawn, in determining whether any sums are excluded by virtue of section 554 from the sums allowable as a deduction in the computation of gains and losses for the purposes of the Capital Gains Tax Acts.
(13) Where an individual is entitled to relief under this section in respect of a subscription by him or her for eligible shares in a company, he or she shall not be entitled to relief in respect of that subscription under section 479.
(14) (a) In this subsection, “distribution” has the same meaning as in the Corporation Tax Acts.
(b) For the purposes of this subsection, an amount specified or implied shall include an amount specified or implied in a foreign currency.
(c) This subsection shall apply to shares in a company where any agreement, arrangement or understanding exists which could reasonably be considered to eliminate the risk that the person beneficially owning those shares—
(i) might, at or after a time specified in or implied by that agreement, arrangement or understanding, be unable to realise directly or indirectly in money or money’s worth an amount so specified or implied, other than a distribution, in respect of those shares, or
(ii) might not receive an amount so specified or implied of distributions in respect of those shares.
(d) The reference in this subsection to the person beneficially owning shares shall be deemed to be a reference to both that person and any person connected with that person.
(e) Relief from income tax shall not be allowed under this Part in respect of the amount subscribed for any shares to which this subsection applies.
(15) This section shall apply only where the shares concerned are issued in the period [2]>commencing on the 6th day of April, 1984, and ending on the [2]>commencing on 6 April 1984 and ending on [1]>5th day of April, 1999<[1][1]>5th day of April, 2001<[1]<[2][5]>31 December 2001<[5][7]>[5]>31 December 2003<[5]<[7][8]>[7]>4 February 2004<[7]<[8][10]>[8]>31 December 2006<[8]<[10][10]>31 December 2013<[10]<[2].
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489 The relief.
(1) This section applies for affording relief from income tax where—
(a) an individual who qualifies for the relief subscribes for eligible shares in a qualifying company,
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(b) those shares are issued to the individual for the purpose of raising money by a qualifying company where that money was used, is being used or is intended to be used by the qualifying company—
(i) for the purposes of carrying on relevant trading activities, or
(ii) in the case of a company which has not commenced to trade, in incurring expenditure on research and development within the meaning of section 766,
and
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(b) those shares are issued to the individual for the purpose of raising money by a qualifying company where that money was used, is being used or is intended to be used by the qualifying company—
(i) for the purposes of carrying on relevant trading activities,
(ii) in the case of a company which has not commenced to trade, in incurring expenditure on research and development within the meaning of section 766, or
(iii) in the case of a company that owns and operates a qualifying nursing home, for the purposes of enlarging the capacity of the qualifying nursing home,
and
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(c) the use of the money as set out in paragraph (b) will contribute directly to the creation or maintenance of employment in the company.
(2) Subject to subsection (3), relief in respect of—
(a) [14]>thirty forty-firsts<[14][14]>thirty fortieths<[14] of the amount subscribed by an individual for any eligible shares shall be given as a deduction from his or her total income for the year of assessment in which the shares are issued, and
(b) subject to subsection (10), [15]>eleven forty-firsts<[15][15]>ten fortieths<[15] of the amount subscribed by an individual for any eligible shares shall be given as a deduction from his or her total income for the year of assessment following the date on which the relevant period ends.
(3) Where—
(a) in accordance with section 506, relief is due in respect of an amount subscribed as nominee for a qualifying individual by the managers of a designated fund, and
(b) the eligible shares in respect of which the amount is subscribed are issued in the year of assessment following the year of assessment in which that amount was subscribed to the designated fund,
then the individual may elect by notice in writing to the inspector to have the relief due under subsection (2)(a) given as a deduction from his or her total income for the year of assessment in which the amount was subscribed to the designated fund, instead of (as provided for in subsection (2)(a)) as a deduction from his or her total income for the year of assessment in which the shares are issued.
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(3A) Notwithstanding subsection (3), where—
(a) in accordance with section 506, relief is due in respect of an amount subscribed between 1 January 2014 and 31 December 2014 as nominee for a qualifying individual by the managers of a designated fund, and
(b) the eligible shares in respect of which the amount is subscribed are issued between 1 January 2016 and 31 January 2016,
the individual may elect by notice in writing to the inspector to have the relief due under subsection (2)(a) given as a deduction from his or her total income for the year of assessment in which the amount was subscribed to the designated fund instead of (as provided for in subsection (2)(a)) as a deduction from his or her total income for the year of assessment in which the shares are issued.
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(4) The relief under subsection (2)(a) shall be given on a claim and shall not be allowed—
(a) in the case of a company which had commenced relevant trading activities at the time the eligible shares were issued, unless and until the company has carried on those activities for 4 months, or
(b) in the case of a company which had not commenced relevant trading activities at the time the eligible shares were issued, unless the company—
(i) begins to carry on relevant trading activities within 2 years after that time, or
(ii) expends not less than 30 per cent of the money subscribed for the shares on research and development activities which are connected with and undertaken with a view to the carrying on of the relevant trading activities.
(5) Subject to subsections (4) and (10) a claim for relief may be allowed at any time if the conditions for the relief are then satisfied.
(6) In the case of a claim allowed before the end of the relevant period, the relief shall be withdrawn if by reason of any subsequent event it appears that the claimant was not entitled to the relief allowed.
(7) Where by reason of its being wound up, or dissolved without winding up, the company carries on relevant trading activities for a period shorter than 4 months, then subsection (4)(a) shall apply as if it referred to that shorter period but only if it is shown that the winding up or dissolution was for bona fide commercial reasons and not as part of a scheme or arrangement the main purpose or one of the main purposes of which was the avoidance of tax.
(8) Subject to section 504, no account shall be taken of the relief, in so far as it is not withdrawn, in determining whether any sums are excluded by virtue of section 554 from the sums allowable as a deduction in the computation of gains and losses for the purposes of the Capital Gains Tax Acts.
(9) (a) In this subsection “distribution” has the same meaning as in the Corporation Tax Acts.
(b) For the purposes of this subsection, an amount specified or implied shall include an amount specified or implied in a foreign currency.
(c) This subsection applies to shares in a company where any agreement, arrangement or understanding exists which could reasonably be considered to eliminate the risk that the person beneficially owning those shares—
(i) might, at or after a time specified in or implied by that agreement, arrangement or understanding, be unable to realise directly or indirectly in money or money’s worth an amount so specified or implied, other than a distribution, in respect of those shares, or
(ii) might not receive an amount so specified or implied of distributions in respect of those shares.
(d) The reference in this subsection to the person beneficially owning shares shall be deemed to be a reference to both that person and any person connected with that person.
(e) Relief from income tax shall not be allowed under this Part in respect of the amount subscribed for any shares to which this subsection applies.
(10) An amount shall not be given as a deduction by virtue of subsection (2)(b) unless in relation to a qualifying company—
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(a) (i) the employment relevant number exceeds the employment threshold number, and
(ii) the average relevant amount is not less than the average threshold amount except to the extent that such difference corresponds with a general reduction in the basic pay rate of qualifying employees in the same period,
or
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[18]>
(a) (i) the employment relevant number exceeds the employment threshold number by at least one qualifying employee, and
(ii) the relevant amount exceeds the threshold amount by at least the total emoluments of one qualifying employee in the year of assessment in which the relevant period ends,
or
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(b) the amount of expenditure on research and development incurred by the qualifying company in the specified relevant period ending in the year of assessment preceding the year of assessment in which, in relation to the subscription for eligible shares, a relevant period ends, exceeds the amount of expenditure on research and development incurred by the qualifying company in the specified relevant period ending in the year of assessment preceding the year of assessment in which the subscription for eligible shares was made.
(11) A company carrying on green energy activities shall be deemed to have commenced relevant trading activities when it has made an application for a grid connection agreement.
(12) The Revenue Commissioners may require the qualifying company to provide to them such evidence as they consider necessary and may consult with such persons or body of persons as in their opinion may be of assistance to them, to enable them to verify that the conditions necessary for the claiming and granting of the relief have been satisfied.
(13) This section shall apply only where the eligible shares are issued on or before [13]>31 December 2013<[13][13]>31 December 2020<[13].
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Chapter 2
Qualifying companies
489. Interpretation (Chapter 2)
(1) In this Part—
‘EEA Agreement’ means the Agreement on the European Economic Area signed at Oporto on 2 May 1992, as adjusted by the Protocol signed at Brussels on 17 March 1993;
‘EEA State’ means a state which is a contracting party to the EEA Agreement;
‘financial activities’ means the provision of, and all matters relating to the provision of, financing or refinancing facilities by any means which involves, or has an effect equivalent to, the extension of credit;
‘financial assets’ includes shares, gilts, bonds, foreign currencies and all kinds of futures, options and currency and interest rate swaps, and similar instruments, including commodity futures and commodity options, invoices and all types of receivables, obligations evidencing debt (including loans and deposits), leases and loan and lease portfolios, bills of exchange, acceptance credits and all other documents of title relating to the movement of goods, commercial paper, promissory notes and all other kinds of negotiable or transferable instruments;
‘financing or refinancing facilities’ includes—
(a) loans, mortgages, leasing, lease rental and hire-purchase, and all similar arrangements,
(b) equity or other investment,
(c) the factoring of debts and the discounting of bills, invoices and promissory notes, and all similar instruments, and
(d) the underwriting of debt instruments and all other kinds of financial securities;
‘linked businesses’ means two or more businesses that are regarded as linked enterprises, within the meaning of Annex 1 of the General Block Exemption Regulation;
‘partner businesses’ means two or more businesses that are regarded as partner enterprises, within the meaning of Annex 1 of the General Block Exemption Regulation;
‘qualifying subsidiary’, in relation to a company, means a subsidiary of that company of a kind which a company may have by virtue of section 492;
‘relevant trading activities’ means activities carried on in the course of a trade the profits or gains of which are charged to tax under Case I of Schedule D, excluding activities related to—
(a) adventures or concerns in the nature of trade,
(b) dealing in commodities or futures or in shares, securities or other financial assets,
(c) financing activities,
(d) the provision of professional services (within the meaning of section 128F(1)),
(e) dealing in or developing land,
(f) the occupation of woodlands within the meaning of section 232,
(g) operating or managing hotels, guest houses, self catering accommodation or comparable establishments or managing property used as an hotel, guest house, self catering accommodation or comparable establishment, except where such activity is a tourist traffic undertaking (within the meaning of section 491),
(h) operations carried on in the coal industry or in the steel and shipbuilding sectors, and
(i) the production of a film (within the meaning of section 481);
‘RICT group’ means the company concerned (that is to say the company referred to in the provision concerned of this Part), its partner businesses and linked businesses, and references to a RICT group shall be taken to refer to any RICT group of which the company is part, and—
(a) for the purposes of section 496(5), includes any company that was, at any time, part of a RICT group with the qualifying company or its qualifying subsidiaries but has since been disposed of,
(b) for the purposes of sections 500, 508P and 508R, includes any company which is at any point during the compliance period a subsidiary of the qualifying company, whether it becomes a subsidiary before, during or after—
(i) the year of assessment in respect of which the individual concerned claims relief and whether or not it is such a subsidiary while he or she is a partner, director or employee, or has an interest in the capital of the company, mentioned in section 500(2)(b), or
(ii) the individual concerned receives any value from it;
‘SME’ means a RICT group that would fall within the SME category of Annex 1 of the General Block Exemption Regulation;
‘unlisted’, in respect of a company, means a company none of whose shares, stock or debentures (within the meaning of section 2 of the Companies Act 2014) are listed in the official list of a stock exchange, or quoted on an unlisted securities market of a stock exchange other than—
(a) on the market known as the Enterprise Securities Market of the Irish Stock Exchange, or
(b) on any similar or corresponding market of the stock exchange—
(i) in a Member State, or
(ii) in an EEA state other than the State.
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[6]
Inserted by FA04 s18(1)(a)(i). Has come into operation and have taken effect as on and from 1 January 2004.
[7]
Substituted by FA04 s18(1)(a)(ii). Has come into operation and have taken effect as on and from 1 January 2004.
[12]
Substituted by FA11 s33(1)(a). Has effect in respect of shares issued on or after 25 November 2011. Note: FA 12 s26 (2) amends FA 11 s33 and provides: (b) This section does not have effect in respect of shares issued before 25 November 2011 and, for all the purposes of Part 16 in connection with those shares, the Principal Act has effect as if this section had not been enacted. (c) This section does not have effect in respect of shares issued on or after 25 November 2011 and on or before 31 December 2011 where— (i) the company issuing the shares, or (ii) where the shares are acquired by an investment fund, the fund acquiring the shares, elects by notice in writing to the Revenue Commissioners on or before 31 December 2011 that, for all the purposes of Part 16 in connection with those shares, the Principal Act has effect as if this section had not been enacted.
[13]
Substituted by FA13 s22(1)(b). Comes into operation on such day or days as the Minister for Finance may by order or orders appoint and different days may be appointed for different purposes or different provisions.
[14]
Substituted by FA14 s27(1)(b)(i). Applies for the year of assessment 2015 and subsequent years.
[15]
Substituted by FA14 s27(1)(b)(ii). Applies for the year of assessment 2015 and subsequent years.
[16]
Substituted by FA15 s18(2)(b)(i). Applies to shares issued on or after 13 October 2015.
[18]
Substituted by FA15 s18(2)(b)(iii). Applies to shares issued on or after 13 October 2015.