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EIS
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EIS
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Private client review for March 2026
Sophie Dworetzsky
From AI in court to IHT and judicial review, Sophie Dworetzsky
(Lombard Odier) reviews the latest developments.
Five (S)EIS pitfalls for the unwary
Philip Hare
Administrative errors can jeopardise SEIS and EIS relief, even when advance
assurance has been received from HMRC, as Philip Hare (Philip Hare &
Associates) explains.
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up
Oliver Twentyman
Many advisers appear to be adopting a contrived and narrow interpretation of
the word ‘preferential’ in an attempt to provide commercial protection to EIS
investors on a winding-up, warns Oliver Twentyman (Azets).
EIS disqualifying arrangements: jumping through the Hoopla
Tom Wilde
Tom Wilde (Shoosmiths) examines an Upper Tribunal decision that raises some interesting points for EIS practitioners.
York SD Ltd and others v HMRC
Shares in solar electricity companies did not qualify for EIS reliefs
Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC
Arrangements relating to animation
project were disqualifying for EIS.
Putney Power Ltd and another v HMRC
Company did not commence trading before EIS deadline.
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).
Other cases that caught our eye: 24 May 2024
Discovery assessment on pension scheme charges upheld: L Trachtenberg v HMRC [2024] UKFTT 376 (TC) (9 May) involves another challenge to the scope of the discovery provisions, this time concerning pension scheme unauthorised payments charges...
Other cases that caught our eye: 17 May 2024
Post-cessation trade relief/notice of enquiry into return: There are two distinct aspects to A Dennison v HMRC [2024] UKFTT 364 (TC) (2 May 2024). The substantive issue is whether or not the taxpayer was entitled to claim relief under the...
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Rebecca Seeley Harris
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Muller: notional companies and real-world transactions
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Burlington: towards an international fiscal meaning of ‘main purpose’
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Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
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Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
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Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
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Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
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HMRC v Healthspan Ltd
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Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
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Ask an expert: Dividend planning under the new close company reporting regime