Cases where maximum investment relief not obtainedU.K.
52(1)Where—U.K.
(a)the amount of the reduction (“C”) in the investing company’s liability to corporation tax obtained in respect of the relevant shares, is less than
(b)the amount (“D”) which is equal to 20% of the amount subscribed by the investing company for those shares,
paragraph 47 has effect as if the amount of the value received were reduced by multiplying it by the fraction—
(2)Where the amount of investment relief attributable to any of the relevant shares has been reduced before the investment relief was obtained, the amount of the corporation tax reduction obtained in respect of those shares shall be deemed for the purposes of sub-paragraph (1) to be the amount of the corporation tax reduction that would have been obtained had no such reduction of relief been made before the relief was obtained.
(3)Sub-paragraph (2) does not apply to a reduction of investment relief by virtue of paragraph 45(4) (attribution of investment relief where there is a corresponding issue of bonus shares).