Related Commentary  Related HMRC Manuals

169VU(1)  For the purposes of this Chapter (other than this subsection) a person “subscribes for” a share in a company if–

(a)that person subscribes for the share,

(b)the share is issued to that person by the company for consideration consisting wholly of cash,

(c)the share is fully paid up at the time it is issued,

(d)the share is subscribed for, and issued, for genuine commercial reasons and not as part of arrangements the main purpose, or one of the main purposes, of which is to secure a tax advantage to any person, and

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