Revenue Note for Guidance

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Revenue Note for Guidance

S508Q Qualification to section 508P for specified persons

Summary

SURE investors who make their initial investment by way of a loan to a company (instead of investing in shares) qualify for the relief.

Details

(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 of the conversion of the loan into eligible shares provided that the business plan (within the meaning of section 493) on which the relevant investment is based was prepared in advance of the loan.

Relevant Date: Finance Act 2024