In order for a person to be treated as having ‘subscribed for’ shares (for the purposes of the definition of qualifying shares (see ¶573-630) and potentially qualifying shares (see ¶573-685)), the following conditions must be satisfied:

the person subscribed for the shares;

the share was issued to the person for consideration wholly in cash;

the share was fully paid up at the date of issue;

the share was 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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