VCM91190 - CVS: investors and reliefs: purpose of making the investment
FA00/SCH15/PARA14
The company must subscribe for the shares for commercial reasons. The subscription must not be part of a scheme or arrangement one of whose main purposes is the avoidance of tax. Before any case is challenged on either of these grounds a report should be made to CTIAA (Structure, Incentives & Reliefs team).