Osmond, Eastern Power Networks and HMRC’s guidance on their new unilateral APA process are among the developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Osmond: an effect or consequence is not a main purpose
The Upper Tribunal (UT) in Osmond and another v HMRC [2025] UKUT 183 (TCC) had to consider whether the main purpose test in the transactions in securities rules in ITA 2007 s 684 was satisfied and concluded in favour of the taxpayers that it was not.
The taxpayers had made successive EIS investments over a 30-year period with a view to realising capital gains and had been careful to preserve their EIS relief CGT benefit. Fearing a withdrawal of EIS...
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Osmond, Eastern Power Networks and HMRC’s guidance on their new unilateral APA process are among the developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Osmond: an effect or consequence is not a main purpose
The Upper Tribunal (UT) in Osmond and another v HMRC [2025] UKUT 183 (TCC) had to consider whether the main purpose test in the transactions in securities rules in ITA 2007 s 684 was satisfied and concluded in favour of the taxpayers that it was not.
The taxpayers had made successive EIS investments over a 30-year period with a view to realising capital gains and had been careful to preserve their EIS relief CGT benefit. Fearing a withdrawal of EIS...
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:
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