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Substantial disappointment
Key points
- A company incorporated a new subsidiary before effecting a sale.
- Extension to the substantial shareholdings exemption arising from FA 2011.
- Tribunal concluded the exemption did not apply to stand-alone trading companies.
- Did parliament intend it should apply only to a group member?
- The current interpretation has no discernible policy behind it.
Oscar Wilde might have said that there is only one thing in the world worse than being mentioned in a tax case and that is not being mentioned in a tax case. I was quite excited to be alerted by a friend to the fact that I had been mentioned in a First-tier Tribunal case specifically M Group Holdings Ltd (TC8054). I was slightly disappointed to discover that the judge decided that my words of wisdom had no weight in helping him reach a decision and that the company lost which suggests...
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