COCONUT ANIMATED ISLAND LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00075 (TCC)

Upper Tribunal Tax and Chancery decision of Judge Greg Sinfield and Ashley Greenbank on 25th March 2024

Read full decision in Coconut Animated Island v HMRC final

SEED ENTERPRISE INVESTMENT SCHEME – whether arrangements for issuing shares were “disqualifying arrangements” – whether Condition A in s257CF(3) Income Tax Act 2007 met – scope of “arrangements” in s257HJ – meaning of “relevant person” and “party to the arrangements” in s257CF(6)

Published 25 March 2024