Part 14Income tax liability: miscellaneous rules
F1Chapter A1Remittance basis
F2Business investment relief
809VCQualifying investments
(1)
For the purposes of section 809VA, a person makes an investment if—
(a)
shares in a company are issued to F3or acquired by the person, or
(b)
the person makes a loan (secured or unsecured) to a company.
(2)
The company is referred to as “the target company”.
(3)
The shares or the person's rights under the loan (or both) forming the subject of the investment are referred to as “the holding”.
(4)
The investment counts as a “qualifying investment” if F4—
(a)
the investment is made before 6 April 2028,
(b)
none of the money or other property used to make the investment is TRF capital, and
(c)
conditions A and B are met when the investment is made.
(5)
Conditions A and B are defined in sections 809VD and 809VF.
(6)
A reference in this section to “shares” includes any securities.
(7)
If a loan agreement authorises a company to draw down amounts of a loan over a period of time—
(a)
entry into the agreement does not count for the purposes of this section as the making of a loan, but
(b)
a separate loan is to be treated as made each time an amount is drawn down under the agreement.
(8)
Accordingly—
(a)
a separate investment is treated as made each time an amount is drawn down under the agreement, and
(b)
the reference in subsection (3) to the person's rights under the loan applies only to so much of the person's rights as relate to the drawdown of that particular amount.