The taxpayer was a director of an AIM listed company. Whilst a director he acquired a shareholding in the company through a share placing. He has a contract note showing the shares being purchased at the placing price with a line on the contract note stating 'RESULT OF PLACING'. Also, the contract note shows the shareholding cost and stockbroker's commission but no stamp duty. Does this method of acquisition satisfy the requirements of ITA2007 s135 where the 'individual subscribes for shares' ? The AIM company is now in liquidation with no prospect of a capital return, so a claim under s131 for Income Tax relief for the capital loss is desired.
22nd Mar 2011
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Shareholding acquired through a share placing
Shareholding acquired through a share placing