There are three types of share which may be contained in a holding of shares immediately before a disposal of all or part of that holding:

(a)qualifying shares;

(b)potentially qualifying shares;

(c)excluded shares.

A share is a ‘qualifying share’ at any time if it meets the following conditions:

(a)it was subscribed for by the person making the disposal (‘the investor’);

(b)the investor has held the share continuously from issue until immediately before the disposal (‘the share-holding period’);

(c)the share was issued on or after 17 March 2016;

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