Income Tax Act 2007 section 257DI

The gross assets requirement

Section 257DI sets out the maximum gross asset value that a company (or group) may hold immediately before issuing shares that qualify for Social Investment Tax Relief.

• Where a single company issues relevant shares, the total value of the company's gross assets must not exceed £350,000 immediately before the shares are issued.
• Where a parent company issues relevant shares, the combined gross assets of the group must not exceed £350,000 immediately before the shares are issued.
• Group assets are calculated by adding together the gross assets of every group member, but ignoring any assets that represent rights against, or shares in or securities of, another member of the same group.
• The purpose of excluding intra-group balances and holdings is to prevent the same value being counted more than once when assessing whether the group meets the threshold.