SCIT CAPITAL GAINS TAX – relief for re-investment under the enterprise investment scheme – Appellant issued shares in return for cash and on the same day issued shares of the same class to convert certain loan notes and in satisfaction of a fee for providing a guarantee — whether all the shares comprised in the issue were issued in order to raise money for the purpose of a qualifying business activity – no -whether investor who had given the guarantee and investors who held loan notes received value from the company – yes – appeal dismissed – TCGA 1992 Section 150C and Sch 5B para 1(2)(f), 13(2)(b) and (c) and 19(1) and (3)(a).
Citations:
[2008] UKSPC SPC00701
Links:
Jurisdiction:
England and Wales
Capital Gains Tax
Updated: 07 April 2022; Ref: scu.273106