Revenue Note for Guidance
SURE investors who make their initial investment by way of a loan to a company (instead of investing in shares) qualify for the relief.
(1) A specified individual will not have received value from a company (by reference to section 508P(3)(b)) where –
An investment in the company by the specified individual was by means of a loan, and the loan is converted into eligible shares within one year of the making of the loan and the specified individual provides a statement by the company’s auditor that the money raised by the loan was used by it solely for a qualifying purpose.
(2) Conversion of the loan into eligible shares is treated as the making of a relevant investment by the specified individual on the date the loan was made.
Relevant Date: Finance Act 2021