SEIS relief claim rejected:Coconut Animated Island Ltd v HMRC[2024] UKUT 75 (TCC) (25 March 2024)is the UT’s decision in the taxpayer’s appeal against the FTT’s decision to uphold HMRC’s refusal to grant relief under the SEIS regime to investors in a company set up to exploit the right to a TV production ‘Coconut Bay’. The key issue was whether or not (in simple terms) the company was sufficiently distanced from an existing media group or whether there were arrangements in place under which the amount raised under the SEIS issue (or the greater part) was paid to persons who were party to the arrangements i.e. the media group or persons connected with it. The FTT had concluded that the ‘fingerprints of the media group’ were all over the arrangements and that therefore no relief was due. The UT endorsed this conclusion. Some of the arguments put...
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SEIS relief claim rejected:Coconut Animated Island Ltd v HMRC[2024] UKUT 75 (TCC) (25 March 2024)is the UT’s decision in the taxpayer’s appeal against the FTT’s decision to uphold HMRC’s refusal to grant relief under the SEIS regime to investors in a company set up to exploit the right to a TV production ‘Coconut Bay’. The key issue was whether or not (in simple terms) the company was sufficiently distanced from an existing media group or whether there were arrangements in place under which the amount raised under the SEIS issue (or the greater part) was paid to persons who were party to the arrangements i.e. the media group or persons connected with it. The FTT had concluded that the ‘fingerprints of the media group’ were all over the arrangements and that therefore no relief was due. The UT endorsed this conclusion. Some of the arguments put...
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