CVS: investors and reliefs: receipt of value: reduction of relief
FA00/SCH15/PARA47 & PARA51
Where investment relief falls to be reduced because of a receipt of value, the amount of the reduction is either the amount of the relief originally obtained (or that amount as reduced on account of any earlier receipt of value) or 20% of the amount of the value, whichever is smaller. But where the amount of the relief obtained was less than 20% of the amount subscribed in the first place, (for example, because there was insufficient liability to corporation tax to enable the subscription to be fully relieved), the amount of the reduction is to be restricted in the same proportion.
If the date when the value is received falls within the periods of restriction related to more than one issue of shares in respect of which relief has been obtained, the reduction to be made is apportioned between the issues in proportion to the amounts subscribed for each issue.