Revenue Note for Guidance

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Revenue Note for Guidance

600G Subscription for shares

Summary

Section 600G sets out the meaning of “subscribes for”.

Details

(1)An individual subscribes for shares if the individual subscribes for and is issued shares by the company—

  1. (1)(a)for consideration consisting wholly of cash,
  2. (1)(b)for bona fide commercial reasons. Thus, the subscription and issue of the shares is for genuine commercial reasons and not as part of arrangements the main purpose, or one of the main purposes, of which is to secure a tax advantage to any person, and
  3. (1)(c)at an arm”s length bargain.

(2)A share subscribed for, issued to, held by, or disposed of for, an individual by a nominee are treated as done by the individual for whom they are acting where the nominee has complied with sections 892 and 894 TCA 1997 in respect of the share.

(3)References to an individual having subscribed for a share include the individual having subscribed for the share jointly with any other individual.

Relevant Date: Finance Act 2024