CITM9020 | Definitions: Meaning of “issue of securities or shares”
From HM Revenue & Customs · Community investment tax relief manual
CTA2010/Part 7/Chapter 6/S265; ITA/s378
For the purposes of the CITR scheme
an issue of securities or shares means all those securities with the same terms or rights, or shares of the same class, as are issued on the same day, and
an issue of securities or shares in a body to a person means all the securities or shares issued to that person in one capacity (so shares or securities issued to a company in its own right are distinguished from those which are issued to it as a trustee)
Shares are not regarded as being in the same class unless they would be treated as such if they were dealt with on the Stock Exchange (CTA2010/S269 & ITA/s382).