COCONUT ANIMATED ISLAND LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00075 (TCC)

Upper Tribunal Tax and Chancery decision of Judge Greg Sinfield and Ashley Greenbank on 25th March 2024

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SEED ENTERPRISE INVESTMENT SCHEME � whether arrangements for issuing shares were “disqualifying arrangements� � whether Condition A in s257CF(3) Income Tax Act 2007 met � scope of “arrangements� in s257HJ � meaning of “relevant person� and “party to the arrangements� in s257CF(6)

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Published 25 March 2024