EIS film investment eligibility rejected despite advance assurance and meeting the Risk to Capital condition
The case of Hoopla Animation Ltd v HMRC in which the Upper Tribunal dismissed an appeal relating to the eligibility of shares in a pre-school television venture's Special Purpose Vehicle (SPV) for Enterprise Investment Scheme (EIS) relief purposes. A member of a group of companies who had provided subcontracting services to the SPV was 'party to' the arrangements
EIS income tax relief tax claim importance for CGT relief reiterated
The case of Kalay v Revenue and Customs (UKFTT 366 (TC) 01 May 2024), in which the taxpayer was unsuccessful in claiming EIS CGT relief because they had not claimed EIS income tax relief. It broadly mirrors R Ames v HMRC (2018) UK UT190 in application of the EIS rules, if not the circumstances governing HMRC’s conduct