Income Tax Act 2007 section 257DH

The no partnerships requirement

Section 257DH prohibits the issuing company and any of its qualifying 90% subsidiaries from being a member of a partnership at any time during period A.

• During period A, neither the issuing company nor any qualifying 90% subsidiary may be a member of a partnership.
• The definition of partnership is broad, covering standard partnerships, limited liability partnerships, and equivalent foreign entities.
• The term "member" is interpreted accordingly, meaning any form of participation in such a partnership structure is caught by the restriction.
• This requirement ensures that SEIS relief is directed at straightforward corporate structures rather than businesses operating through partnership arrangements.