.png)
.png)
12 November 2007
Categories:
Tax cases
Blackburn and another (SpC 606)
In July 1998 B contracted to buy a sports club for £111 000. In August he incorporated the second appellant company to own and operate the club with himself and his wife as directors and his wife also company secretary. B owned all the shares in the company except for one share owned by his wife. Between 1998 and 2000 the company made six issues of shares to B.
B claimed enterprise investment scheme relief in respect of all the shares but HMRC rejected the claim.
The main issues were:
- whether all the shares were fully paid up;
- whether TCGA 1992 Sch 5B para 13(2)(b) applied to all the shares;
- whether all the shares were subscribed for in cash.
The Special Commissioner said that the issue of the shares had been muddled with some being registered...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
