The rules in ITA 2007 s 247 which preserve EIS relief and FA 1986 s 77 which provides relief from stamp duty – in each case on the introduction of a new holding company – are highly prescriptive. A number of technical challenges arise, including dealing with the subscriber shares in the new holding company and ensuring a ‘mirror image’ between the shareholdings in the target company and the new holding company. In some cases, it may not be possible to overcome the challenges and satisfy the requirements of both sets of rules.
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