The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Euromoney: statutory purpose test
Euromoney v HMRC [2021] UKFTT 61 (TC) is the latest case on the application of a statutory purpose test to be decided in favour of the taxpayer. It involved the sale of shares in two companies CDL and CNL and initially the consideration was going to be a mixture of cash and ordinary shares in the purchaser. There were commercial reasons for the taxpayer wanting to own shares in the purchaser but the purchaser also wanted a material amount of cash consideration.
Whereas the sale of the CNL shares would qualify for the substantial shareholding exemption (SSE) the sale of the CDL shares would not (it appears this was because Euromoney had not been entitled to receive a dividend on the CDL shares receiving instead a...
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The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Euromoney: statutory purpose test
Euromoney v HMRC [2021] UKFTT 61 (TC) is the latest case on the application of a statutory purpose test to be decided in favour of the taxpayer. It involved the sale of shares in two companies CDL and CNL and initially the consideration was going to be a mixture of cash and ordinary shares in the purchaser. There were commercial reasons for the taxpayer wanting to own shares in the purchaser but the purchaser also wanted a material amount of cash consideration.
Whereas the sale of the CNL shares would qualify for the substantial shareholding exemption (SSE) the sale of the CDL shares would not (it appears this was because Euromoney had not been entitled to receive a dividend on the CDL shares receiving instead a...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
