Section 257QN | Single issue treated as made partly in previous tax year

(1)This section applies if—

(a)section 257QJ(2) applies to SI relief attributable to shares held by an individual, and

(b)part of the issue of shares has been treated as issued to the individual in a previous tax year for the purposes of section 257JA(1) and (2).

(2)This subsection explains how the calculation under section 257QJ(3) is to be made.

Step 1 Apportion the amount referred to as A between the tax year in which the shares were issued and the previous tax year by multiplying that amount by the fraction—ITwhere—I is the amount on which the individual obtains SI relief in respect of the shares treated as issued in the tax year in question, andT is the total of that amount and the corresponding amount in respect of the shares treated as issued in the other tax year.

Step 2 In relation to each of the amounts (“A1” and “A2”) so apportioned to the two tax years, calculate the amounts (“X1” and “X2”) that would be given by the formula if there were separate issues of shares in those tax years. In calculating amounts X1 and X2, apply section 257QO if appropriate but do not apply section 257QL or 257QM.

Step 3 Add amounts X1 and X2 together. The result is the required amount.