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6U.K.If a company so elects, the amendments made by this Schedule do not have effect in relation to shares issued by the company—
(a)before 18 December 2008, or
(b)on or after that date under an agreement entered into before that date.
7U.K.An election under paragraph 6—
(a)must be made by the company by being included in its company tax return for the first accounting period of the company beginning on or after 1 January 2008 (and may be included in the return originally made or by amendment), and
(b)is irrevocable.