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Conegate v HMRC

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In Conegate v HMRC [2018] UKFTT 82 (13 February 2018) the FTT found that losses claimed in relation to a repurchase of shares were not allowable.

Conegate was an investment company of which Mr Sullivan was the director and sole shareholder. Conegate (as well as Roldvale a pension fund instituted for the benefit of Mr Sullivan) had entered into a subscription and shareholder agreement in respect of a company called WHH which owned West Ham United Football Club. As a result they owned 50% of WHH whilst the other 50% remained owned by CBH. Mr Sullivan started to look for ways of raising funds for the club. On the advice of his lawyers Conegate implemented a set of transactions which involved the purchase of an additional 200 ordinary shares by Conegate and Roldvale. Those shares were converted into 200...

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