Seed Enterprise Investment Scheme – Appeal from A Refusal To Authorise The Issue of A Compliance Certificate in relation to certain issues of shares made by the Appellant – held that the refusal was justified – although (i) having regard to all the circumstances existing at the time of each share issue, the Appellant had objectives to grow and develop its trade in the long-term (so that the risk-to-capital condition requirement was satisfied) and (ii) the Appellant did not carry on ‘excluded activities’ by virtue of receiving royalties or licence fees because those royalties and licence fees were attributable to the exploitation of ‘relevant intangible assets’ (so that the trading requirement was met), the arrangements pursuant to which the Appellant had issued the relevant shares and applied the proceeds in the course of its trade were ‘disqualifying arrangements’, with the result that the general requirements in respect of the relevant shares were not met – appeal dismissed
Citations:
[2022] UKFTT 303 (TC)
Links:
Jurisdiction:
England and Wales
Taxes – Other
Updated: 20 September 2022; Ref: scu.680700