S507 The relief (SURE)

(1) Where a specified individual (as defined) makes a relevant investment in a qualifying company, shall be entitled to relief in respect of that relevant investment. The relief will be given as a deduction from his/her total income for the year of assessment in which the shares are issued.

(2) For the purposes of a SURE investment, in any one year of assessment, the maximum relevant investment which a person may claim is €100,000.

(3)(a) A specified individual may elect to have the relief given as a deduction from that individuals income in any one of the years of assessment that comes immediately before the year of assessment in with the eligible shares for that investment are issued instead of claiming the relief in the year the shares are issued. This election must be made in writing to the Revenue Commissioners. If such an election is made, the shares will be deemed to have issued in the nominated year.

(3)(b) Where a specified individual makes a second SURE investment-

• in the same company as the first such investment, and
• within the 2 tax years following the tax year in which the initial such investment is made,

the relief due for the second investment is given as a deduction from the investor’s total income for any one or more of the 6 tax years, which he/she nominates, immediately before the tax year in which the eligible shares were issued in respect of the first such investment. The nominated year may be the same or different to that nominated in respect of that first such investment. Again, for the purpose of granting relief only, but subject to the limits set out in this paragraph (c) and (d) of this subsection, the shares which are issued in respect of the investment are deemed to have issued in the nominated year.

(3)(c) Any unabsorbed relief in respect of both the first and second SURE investments is carried forward to the tax years nominated by the individual for this purpose between the tax year originally nominated and the tax year in which the shares actually issued in respect of the first such investment.

This procedure ensures that tax refunds for up to 6 years are paid to the individual.

(3)(d) Any relief still outstanding in respect of the first or second SURE investment is given in the year in which the shares are actually issued.

(3)(e) No more than two relevant investments can be made by a specified individual on or after 2 June 1995.

(3)(f) This applies notwithstanding any limitation in section 865(4) or section 959V(6) on the time within which a claim for a repayment of tax is required to be made. Any excess tax paid may be repaid on foot of a timely (within the time limits set out in section 508G) and valid claim within the meaning of section 865(1)(b). (The meaning of a valid claim is dealt with in section 865).

Relevant Date: Finance Act 2021