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Risk of ERS challenge by HMRC?

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Hi,

My client is raising funds through SEIS (advance assurance already received). They are now at the point of wanting to issue the shares. I wanted to check whether which, if any, of the below approaches may lead to a challenge by HMRC from an ERS point of view for the founder, and more generally, what your advised approach would be.

The current shareholding is £1 owned by the founder. The new investor will own 15% of share capital.

Approach 1: share split, such that founder owns 85 shares, worth £0.0117647 each. The company then allots 15 more shares to the new investor for £50k

Approach 2: share split, such that the founder owns 10000 shares, worth £0.0001 each. The company then allots 1765 shares to the new investor for £50k

Approach 3: 84 shares are alloted to founder for £84. The company then allots 15 shares to the new investor for £50k

Appreciate your thoughts!

Thanks

Oliver

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