Natasha Kaye and Jacob Gilkes consider the EIS and stamp duty provisions which apply when introducing a new holding company
The recent First-tier Tribunal (FTT) decision in Finn & Others v HMRC [2014] UKFTT 426 (TC) demonstrates the highly prescriptive nature of the rules in ITA 2007 s 247 which are intended to preserve EIS relief on the introduction of a new holding company (Newco). Similarly the rules in FA 1986 s 77 which are intended to provide for relief from stamp duty in the same circumstances are equally prescriptive.
This article highlights some of the technical issues to be aware of and discusses a key tension between these rules which means that in many...
