Revenue Precedents

If a SPIA holder gets income from the SPIA in the form of shares, the shares can be left in the SPIA without breaching the investment limit once the income is not taken out of the SPIA. The investment limit is breached only if the cash given to the designated broker for investment exceeds the limit. After 5 years the balance in the SPIA must be reduced to the prescribed limit. GD93011

The aggregate of the consideration given for shares which are at any time held in a SPIA must be, as respects specified qualifying shares, at least 10% of the aggregate of the consideration given for the assests of the SPIA at that time. GD93011A