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HMRC internal manual

Community investment tax relief manual

Definitions: Meaning of “issue of securities or shares”

CTA2010/Part 7/Chapter 6/S265; ITA/s378

For the purposes of the CITR scheme

  • an issue of securities or shares means all those securities with the same terms or rights, or shares of the same class, as are issued on the same day, and
  • an issue of securities or shares in a body to a person means all the securities or shares issued to that person in one capacity (so shares or securities issued to a company in its own right are distinguished from those which are issued to it as a trustee)

Shares are not regarded as being in the same class unless they would be treated as such if they were dealt with on the Stock Exchange (CTA2010/S269 & ITA/s382).