Taxes Consolidation Act 1997 section 600N

Qualifying partnership

Section 600N provides that angel investor relief may also apply where an individual makes an investment in eligible shares through a qualifying partnership, subject to certain modifications.

• An individual must be a partner in the partnership and must have contributed at least €20,000 to the partnership before it invests in eligible shares in a qualifying company.
• The partnership must be established under a written partnership agreement with a principal business of investing funds in accordance with a defined investment policy, and must meet conditions relating to the handling of funds, payment of dividends, management expenses and the preparation of audited accounts.
• The qualifying partnership must invest at least €20,000 in eligible shares; the option to invest €10,000 where that represents at least 5% of the share capital is not available for partnership investments.
• The effective CGT rate on qualifying gains made through a partnership is 18%, compared with 16% for direct individual investments, reflecting a 15% reduction rather than the 17% reduction available to individual investors.