Fashion On The Block Ltd v HMRC

In Fashion On The Block Ltd v HMRC [2021] UKFTT 306 (TC) (2 September 2021) the FTT allowed the taxpayer company’s appeal for seed enterprise investment scheme (SEIS) relief. In accordance with purposive construction of the SEIS legislation despite the mistaken submission of an EIS1 compliance form there had been no prior EIS investment so the conditions for SEIS relief had been satisfied.

Fashion on the Block Ltd is a start-up fashion technology company incorporated in 2018. The two co-founders used their own capital in the early development phase but recognised that the business would need seed capital to grow. They accordingly planned a share issue and they obtained from HMRC advance clearance that the shares would qualify for income tax relief under the SEIS. The company was successful in raising applications for £150 000 of shares from UK investors the upper limit permitted under...

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