SDLTM24730 - The Seeding Period
The ’seeding period’ means a period:
starting with the effective date on which the first property was seeded into the PAIF or CoCS, and ending on the date of the first ‘external investment’ into the PAIF or CoCS, or
if shorter, the 18-month period beginning with the effective date on which the first property was seeded into the PAIF or CoCS.
The seeding period may end earlier when a valid election to that effect is made. Where an election is made, the date specified in the election will be taken to be the end of the seeding period. The seeding period is read inclusively such that transactions at any time on the first and last date of the period are capable of being relieved.
The ‘first property seeding date’ means the earliest effective date of a transaction that meets Conditions A to C of the basic conditions for relief.
The first external investment refers to the first non-land transaction in which the vendor is an ‘external investor’.
’External investor’ refers to a person other than a person who has been a vendor in a transaction:
With an effective date on or before the ’non-land transaction’; and
Which meets Conditions A to C of the basic conditions for relief.
‘Non-land transaction’ means a transaction in which the PAIF or CoCS acquires assets which do not include a chargeable interest in land.
A mere supplier of equipment or other goods to the PAIF or CoCS is not taken to be an investor and, as such, ‘business as usual’ procurement will by the PAIF or CoCS will not be viewed to amount to external investment in the fund.