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J Halnan v HMRC (and related appeal)

In J Halnan v HMRC (and related appeal) (TC01423 – 12 October) a company (M) ceased trading in 2004 and subsequently went into liquidation. Two of its directors submitted claims for loss relief contending that they had subscribed for shares in M and that the shares had become worthless.

However they failed to provide share certificates in support of their claims and HMRC rejected the claims on the grounds that the directors had not shown that they had subscribed for shares in the company.

The First-tier Tribunal dismissed the directors’ appeals against this decision.

Why it matters: ITA 2007 s 131 provides relief for losses on shares in trading companies subject to certain conditions.

Anyone who wishes to claim relief under this provision will need to provide evidence that he or she has actually subscribed...

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