Paragraph 1 F1

there would (apart from paragraph 2(2)(a) below) be a chargeable gain (“the original gain”) accruing to an individual (“the investor”) at any time (“the accrual time”) on or after 29th November 1994;

the gain is one accruing either on the disposal by the investor of any asset or in accordance with F2section 164F or 164FA, F3section 169N, paragraphs 4 and 5 below or paragraphs 4 and 5 of Schedule 5C;

the investor makes a qualifying investment; and

the investor is resident F4... in the United Kingdom at the accrual time and the time when he makes the qualifying investment and is not, in relation to the qualifying investment, a person to whom sub-paragraph (4) below applies.

eligible shares in a company for which he has subscribed F6... are issued to him at a qualifying time and, where that time is before the accrual time, the shares are still held by the investor at the accrual time,

he subscribed for the shares (other than any of them which are bonus shares) wholly in cash,

the company is a qualifying company in relation to the shares,

at the time when they are issued the shares F8(other than any of them which are bonus shares) are fully paid up,

the shares are subscribed for, and issued, for bona fide commercial purposes and not as part of arrangements the main purpose or one of the main purposes of which is the avoidance of tax,

the total amount of relevant investments made in the company in the year ending with the date the shares are issued does not exceed F10£5 million,

the requirements of section 289(1A) of the Taxes Act F11(read with section 289(1B) to (1E) of that Act)F12, or the requirements of section 183 of ITA 2007, are satisfied in relation to the company,

F13the shares (other than any of them which are bonus shares) are issued in order to raise money for the purpose of a qualifying business activity, F14and

all of the money raised by the issue of the shares (other than any of them which are bonus shares) is, no later than the time mentioned in section 175(3) of ITA 2007, employed wholly for the purpose of that activity,

any time in the period beginning one year before and ending three years after the accrual time, or

any such time before the beginning of that period or after it ends as the Board may by notice allow.

though resident F16... in the United Kingdom at the time when he makes the investment, he is regarded for the purposes of any double taxation relief arrangements as resident in a territory outside the United Kingdom, and

were section 150A to be disregarded, the arrangements would have the effect that he would not be liable in the United Kingdom to tax on a gain arising on a disposal, immediately after their acquisition, of the shares acquired in making that investment.