[257AAA Risk-to-capital condition]
Income Tax Act 2007 (2007 c 3) | Legislation

[257AAA  Risk-to-capital condition]

[(1)     The risk-to-capital condition is met if, having regard to all the circumstances existing at the time of the issue of the shares, it would be reasonable to conclude that—

(a)     the issuing company has objectives to grow and develop its trade in the long-term, and

(b)     there is a significant risk that there will be a loss of capital of an amount greater than the net investment return.

(2)     For the purposes of subsection (1)(b)—

(a)     the risk is to be determined by reference to a loss of capital, and the net investment

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