Revenue Note for Guidance

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Revenue Note for Guidance

Chapter 6 – Administrative requirements and reporting obligations

S508 Carry forward of unused relief

(1) Where due to an insufficiency of total income or the operation of the upper maximum limits set out in section 507 for SURE or section 502 in all other cases per tax year an individual cannot fully utilise his/her relief in the tax year in which the shares are issued, the unused amount may be carried forward to the following year of assessment and treated as an amount directly subscribed for eligible shares issued to that individual in that year. However, the carry forward of relief does not apply to any year after the tax year 2024.

Any amount which has been carried forward to a following year may, if not fully relieved in that following year, may be carried forward to the next year and so on until the full amount is relieved. Amounts so carried forward are treated as an amount directly subscribed for eligible shares in those later years. However, the carry forward of relief does not apply to any year after the tax year 2024.

Priority of relief

Relief is given to an individual for a year of assessment in the following order -

  • (2) firstly, in respect of amounts carried forward from an earlier year of assessment (where amounts are carried forward from more than one year of assessment the earlier amounts are relieved before later amounts), and
  • then, the amounts invested in the current year of assessment.

Relevant Date: Finance Act 2021