A company has lost its appeal at the First-tier Tribunal on the basis that there were disqualifying arrangements – Hoopla Animation Ltd v HMRC [2023] UKFTT 24 (TC). Nevertheless, the FTT rejected certain arguments of both parties.
The FTT reviewed the evidence in detail and accepted that the Appellant had the objective to grow and develop its trade in the long term. The tribunal also rejected HMRC’s arguments in relation to whether there was a qualifying trade, determining that there was indeed such a trade.
However, the FTT also reached an “inescapable conclusion” that there were disqualifying arrangements, and the taxpayer company therefore lost its appeal.
https://www.bailii.org/uk/cases/UKFTT/TC/2022/TC08683.html
Related content from Claritax Books
Enterprise Investment Scheme, by Andrew Rainford, offers a clear explanation of the four types of venture capital relief: EIS, Seed EIS, venture capital trusts, and social investment tax relief.
In each case, the author looks at the range of tax incentives offered by the legislation, including (as appropriate) income tax reliefs, CGT exemptions, CGT deferrals, and relief for losses incurred. The conditions for relief are examined in detail and are illustrated with examples.
