In two separate cases – Coconut Animated Island Ltd v HMRC [2022] UKFTT 303 (TC) (CAI) (23 August 2022) and Valyrian Bloodstock Ltd v HMRC [2002] UKFTT 306 (TC) (VB) (25 August 2022) – the FTT dismissed appeals against HMRC notices refusing permission to issue compliance certificates under the seed enterprise investment scheme and enterprise investment scheme respectively (so denying relief to investors under the schemes).
CAI was formed by a group of companies (the CHF Group) to exploit the intellectual property rights in a pre-school cartoon concept previously created by an employee of the group F. The group retained 49% of the equity with the remaining shares issued to investors. Development and production work was subcontracted to a group member.
VB was established to carry on a business of buying racehorses at 6 to 12 months old and selling at three years plus (known as ‘pinhooking’). All of...
