CIOT spring conference 2012

SPEAKERS

• Philip Hare Pricewaterhouse Coopers
• Carolyn Steppler Ernst & Young
• Rebecca Benneyworth Tax Adviser
• Robert  Jamieson Mercer & Hole

Disqualifying arrangements

Philip Hare explained that although the definition in the new Finance Bill 2012 provision outlawing ‘disqualifying arrangements’ for EIS investments potentially has a very wide impact informal discussions with HMRC indicate they believe the measure to be aimed at schemes with the characteristics identified during the previous consultation process.

This highlighted companies which operated for a relatively short period of time employing no staff and subcontracting their work to other (often larger) companies.

The economic substance (though not the legal form) of such arrangements was that the investee company received a return which was equivalent to the interestthey might otherwise have received and another...