Revenue Note for Guidance

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Revenue Note for Guidance

S508X Treatment of statement of qualification as a return

Summary

This section will apply to statements made under Chapter 6 and will provide for the application of section 1077E to these statements.

Detail

(1)(a) In subsections (2) and (5) of section 1077E, the provision to an investor of -

  1. a statement of qualification
  2. a statement of qualification (second stage) relief, or
  3. a statement of qualification (SURE),

will be treated as the making or deliver of a return by the company.

(1)(b) Subsections (4) and (7) of section 1077E, will mean 25 per cent of the amounts referred to in subsections (1) and (3) of section 508U shall be treated as an amount calculated under section 1077E(11) and where an assessment is made pursuant to section 508W(1)(a)(i), the amount calculated in accordance with section 1077E(11) will be treated as a tax liability of the company which provided the statement to the specified individual.

(1)(c) Subsection (11) of section 1077E will have effect as if a reference to “the person concerned” were references to “the qualifying investor” or “specified individual” as the case may be and references to “that person” were references to “the company which provided the statement to the investor”.

(2) For the purposes of section 1086, where an assessment is made pursuant to section 508W(1)(a)(i) any interest arising under section 1080 will be treated as interest payable by, and the amount calculated under subsection (1)(b)(ii) will be treated as a tax liability of the company which provided the statement to the specified individual.

Relevant Date: Finance Act 2021