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HMRC internal manual

Capital Gains Manual

HM Revenue & Customs
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Groups: indexation allowance restriction: not redeemable preference shares

The definition of `linked company funded subscription’ in TCGA92/S183 (4) refers to finance provided `directly or indirectly’. This covers the possibility that there may be several layers of share subscriptions in linked companies between the linked company subscription-financing loan and the acquisition of the shares in the target company. The phrase `directly or indirectly’ does not extend the scope of the provisions to loans or subscriptions routed through unconnected third parties.