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I've been in argument with HMRC on this
over whether shares had become of negligible value or had always been of negligible value since subscription. A long letter and a comparison to the graffiti artist who accepted facebook shares as payment of a $5k job done for the (then) fledgling company and HMRC backed down. But I've also chanced my arm on milk quota's bought for c£140k and worth about £400 on cessation of trade. Eventually subsequently sold for about £500 less £250 commission. In that case the slightly peculiar decision in Barker, Harper and Wickes v CIR served to support the HMRC assertion that £400 was not negligible, even on a cessation of trade and against the price paid of c£140k.
It certainly seems to be the case that HMRC are increasingly challenging reliefs and exemption (PPR for example) which would, a few years ago, have gone through on the nod. Often with surprising and disappointing outcomes too.
I've been in argument with HMRC on this
over whether shares had become of negligible value or had always been of negligible value since subscription. A long letter and a comparison to the graffiti artist who accepted facebook shares as payment of a $5k job done for the (then) fledgling company and HMRC backed down. But I've also chanced my arm on milk quota's bought for c£140k and worth about £400 on cessation of trade. Eventually subsequently sold for about £500 less £250 commission. In that case the slightly peculiar decision in Barker, Harper and Wickes v CIR served to support the HMRC assertion that £400 was not negligible, even on a cessation of trade and against the price paid of c£140k.
It certainly seems to be the case that HMRC are increasingly challenging reliefs and exemption (PPR for example) which would, a few years ago, have gone through on the nod. Often with surprising and disappointing outcomes too.