In respect of share issues on or after 6 April 2012, the eligible shares (see ¶565-750) must not be issued in consequence of, or in connection with, what are termed ‘disqualifying arrangements’. These are arrangements, not necessarily including the issuing company, where the main purpose of one of the parties is to secure that the company or a qualifying 90 per cent subsidiary (see ¶323-395), carries on the qualifying business activity (see ¶565-850) for which the funds are raised by the share issue and that one or more persons (which may or may not include that party) will obtain a ‘relevant tax relief’ and either:

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