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)