Entrepreneurs’ relief: Mem and arts must make it personal
The tax tribunal refused to make up for deficiencies in a company’s memorandum and articles of association. The rights attached to the taxpayer’s shares didn’t meet the ER conditions and relief was denied.
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A fairly predictable outcome. Nevertheless, probably - to most members here - a decision that is far more interesting and useful than many of the cases touted here as “interesting”
Well, my last mentioned case that you & others here found so uninteresting was featured in both Tax Journal & Taxation Magazine and an ex-judge here found it very interesting, so your above comment says a lot more about you & others here (and your tax knowledge or lack thereof) than me does it not?
As for the above ER case, what is so new & novel & interesting about it? Nothing in my view and it's entirely unsurprising - which is why JGQC gave it short shrift as such a trite point (although pointing out the obvious is of course useful to yourself & others here I suppose).
As someone around here once said
it rather suggests that I'm right and you're wrong if insults is all you have to argue with
The tax tribunal refused to make up for deficiencies in a company's memorandum and articles of association. The rights attached to the taxpayer's shares didn't meet the ER conditions and relief was denied.