Commentary on Sections Overview Overview Section 201: Attribution of EIS relief to shares
655.This section attributes EIS relief for a tax year:
	first, to the issues of shares on which relief is claimed; and
	second, to shares included in those issues.
It is based on section 289B(1) to (3A) and (5) and (6) of ICTA.
656.These attributions are needed because the investor may have subscribed to more than one share issue of a single company, or to share issues of more than one company, during the tax year. Each such share issue to the investor may have different periods associated with it for the purpose of recovery or withdrawal of relief. And the question of whether relief is attributable to shares disposed of is also relevant to relief for losses on shares and for capital gains tax purposes.
657.Subsections (2) to (4) cater for cases where an individual claims EIS relief in respect of all of the shares in relation to which the individual is eligible for relief. They also cater for cases where an individual claims EIS relief in respect of some, but not all, of the shares in relation to which the individual is eligible for relief. See the commentary on section 158 and Change 36 in Annex 1.