Inserting a holding company: EIS and stamp duty considerations

Jacob Gilkes

Natasha Kaye

Natasha Kaye and Jacob Gilkes consider the EIS and stamp duty provisions which apply when introducing a new holding company

The recent First-tier Tribunal (FTT) decision in Finn & Others v HMRC [2014] UKFTT 426 (TC) demonstrates the highly prescriptive nature of the rules in ITA 2007 s 247 which are intended to preserve EIS relief on the introduction of a new holding company (Newco). Similarly the rules in FA 1986 s 77 which are intended to provide for relief from stamp duty in the same circumstances are equally prescriptive.

This article highlights some of the technical issues to be aware of and discusses a key tension between these rules which means that in many cases ...

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Natasha Kaye and Jacob Gilkes consider the EIS and stamp duty provisions which apply when introducing a new holding company

This article highlights some of the technical issues to be aware of and discusses a key tension between these rules which means that in many cases ...

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: