S508O Anti-avoidance: disposal of a qualifying subsidiary

(1)(2) This applies before the end of the relevant period for a qualifying investment, a qualifying company disposes of a qualifying subsidiary (this will include on a winding up or dissolution), and if the amounts raised from the qualifying investment were invested in eligible shares of that qualifying subsidiary, and the amounts raised from that disposal were not returned to the qualifying investors without undue delay. The qualifying investors for the purposes of section 508M, shall be treated as if, on the date of that disposal, they partially disposed of the shares that they hold in the qualifying company for an amount equal to the portion (their shareholding in respect of their eligible shares) of the market value of the qualifying subsidiary on the date it is disposed of, or the amount for which it was disposed if higher.

Relevant Date: Finance Act 2021