As readers will know equity investors must meet certain prescribed conditions to obtain relief under the Enterprise Investment Scheme (‘EIS’). This includes the need to invest in a company that is carrying out a qualifying trade or will do so within two years of the investment; this was the issue in dispute in Putney Power Ltd and another v HMRC [2024] UKFTT 870 (TC).
HMRC denied that shares issued respectively by Putney Power and Piston Heating Services qualified for EIS arguing that the companies had not commenced their trade by 4 April 2018 (the relevant EIS deadline).
HMRC said that because the power stations constructed by the appellant companies for their trade of generating and selling electricity were not producing electricity by the EIS deadline neither was trading. The appellant companies took the position that a trade can commence at an earlier stage than when supply...
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As readers will know equity investors must meet certain prescribed conditions to obtain relief under the Enterprise Investment Scheme (‘EIS’). This includes the need to invest in a company that is carrying out a qualifying trade or will do so within two years of the investment; this was the issue in dispute in Putney Power Ltd and another v HMRC [2024] UKFTT 870 (TC).
HMRC denied that shares issued respectively by Putney Power and Piston Heating Services qualified for EIS arguing that the companies had not commenced their trade by 4 April 2018 (the relevant EIS deadline).
HMRC said that because the power stations constructed by the appellant companies for their trade of generating and selling electricity were not producing electricity by the EIS deadline neither was trading. The appellant companies took the position that a trade can commence at an earlier stage than when supply...
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:
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