Martin Mann (Gabelle) looks back on some of the most significant tax changes affecting SMEs in recent months.
Alberg and Murray-Hession: share loss relief
When corporate businesses fail shareholders will want to claim relief for the loss they have suffered and ideally will look towards a claim under ITA 2007 s 131 against other income.
Two recent cases brought before the First-tier Tribunal – Murray-Hession v HMRC [2016] UKFTT 612 and Alberg v HMRC [2016] UKFTT 621 – considered claims for relief under these provisions in two failed business situations. In both cases the issue was whether the loss claims had cleared the first hurdle of the relief by showing that qualifying shares had been issued within the meaning of ITA 2007 s 135. For this purpose qualifying shares include shares in a trading company for which the individual has subscribed in consideration of money or money’s worth. As often appears to be the...
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Martin Mann (Gabelle) looks back on some of the most significant tax changes affecting SMEs in recent months.
Alberg and Murray-Hession: share loss relief
When corporate businesses fail shareholders will want to claim relief for the loss they have suffered and ideally will look towards a claim under ITA 2007 s 131 against other income.
Two recent cases brought before the First-tier Tribunal – Murray-Hession v HMRC [2016] UKFTT 612 and Alberg v HMRC [2016] UKFTT 621 – considered claims for relief under these provisions in two failed business situations. In both cases the issue was whether the loss claims had cleared the first hurdle of the relief by showing that qualifying shares had been issued within the meaning of ITA 2007 s 135. For this purpose qualifying shares include shares in a trading company for which the individual has subscribed in consideration of money or money’s worth. As often appears to be the...
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:
