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Owen Oyston was the principal shareholder in Segesta Ltd the holding company for shares in Blackpool Football Club at the time of transactions relevant to the appeal.

He made substantial loans to the club and in December 1999 subscribed for a tranche of shares in Segesta. At the same time he received £4 147 413 from Blackpool FC as repayment of loans made previously.

HMRC refused to authorise Segesta to issue a certificate that would allow Mr Oyston to claim reinvestment relief on the shares under the enterprise investment scheme.

Although complicated by the theft of company funds by a third party the First-tier Tribunal rejected the taxpayer company’s appeal on the grounds the shares were not eligible shares under TCGA 1992 Sch 5B paras 13(1) and 13(2) because Mr Oyston had received value from Segesta owing to its...