Arrangements relating to animation project were disqualifying for EIS.
In Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC [2025] UKUT 28 (TCC) (23 January) the Upper Tribunal (UT) considered the taxpayer’s appeal against the FTT decision that HMRC were right to refuse authorisation to the taxpayer to issue EIS compliance certificates on the basis there existed ‘disqualifying arrangements’ for the purposes of ITA 2007 s 178A.
The taxpayer was a special purpose vehicle incorporated to exploit IP in a pre-school animation concept and was part of a group through which third party investors invested in such special purpose vehicles. The intention being that the third party investments would benefit from the seed enterprise investment scheme (SEIS) and enterprise investments scheme (EIS) respectively.
As part of the arrangements the taxpayer entered into a production services agreement (PSA) with another group company under which...
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:
Arrangements relating to animation project were disqualifying for EIS.
In Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC [2025] UKUT 28 (TCC) (23 January) the Upper Tribunal (UT) considered the taxpayer’s appeal against the FTT decision that HMRC were right to refuse authorisation to the taxpayer to issue EIS compliance certificates on the basis there existed ‘disqualifying arrangements’ for the purposes of ITA 2007 s 178A.
The taxpayer was a special purpose vehicle incorporated to exploit IP in a pre-school animation concept and was part of a group through which third party investors invested in such special purpose vehicles. The intention being that the third party investments would benefit from the seed enterprise investment scheme (SEIS) and enterprise investments scheme (EIS) respectively.
As part of the arrangements the taxpayer entered into a production services agreement (PSA) with another group company under which...
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:
2734558d-601b-48a3-8ae3-ae3513a00429.tmb-editorspic.jpg?sfvrsn=1fc4692d_1)
