Another Q on s.24A ITA 2007

Another Q on s.24A ITA2007

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My last question on this did not attract any interest, but perhaps this one will have more luck.  Here's hoping.

If the shares meet all of the qualifying conditions for EIS relief, but no claim for EIS relief was made, do the shares fall within s.131(2)(a) and thereby fall within the exclusion in s.24A(7)(d)(i) so as to allow for full loss relief even where the loss exceeds the higher of £50K and 25% of income?

In other words, does the failure to apply for EIS relief on shares which would have qualified, had an application for such relief been filed, subject those shares to the s.24A cap?

With kind regards

Clint Westwood

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By kaff
24th Oct 2016 07:35

The exclusion from the cap applies if EIS relief is attributable to the shares. For EIS relief to be attributable to the shares it must have been claimed and the investor's tax liability reduced as a result.

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