For this purpose, the historic rule has been that an investment is made if there is an issue of shares or securities in a company to a person, or the making of a loan to a company. Thus exemption has not been available for remittances used to purchase shares or securities from existing holders (ITA 2007, s. 809VC(1); (6)).

However, per Finance (No. 2) Act 2017 amendment, the scope of the existing provision was widened, and an investment is also made if shares or securities in a company are acquired by a person: this amendment has effect from 6 April 2017.

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