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McLocklin: indirect subscriptions of share capital

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McLocklin v HMRC [2014] UKFTT 042 (TC) involved a successful claim for share loss relief in circumstances where freshly issued shares were registered in the name of and paid for by a third party, and then subsequently sold to the taxpayer. McLocklin shows a court applying taxing statutes in a non-avoidance context by reference to the totality of the arrangements entered into. Such an approach gives practitioners a helpful tool to use in settlement negotiations with HMRC, as it arguably provides the parties with an avenue to avoid the dreaded ‘all or nothing’ classification under HMRC’s inflexible litigation and settlement strategy.

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