In Euromoney Institutional Investor PLV v HMRC [2021] TC08046, HMRC was unsuccessful in blocking a company's claim for share-for-share relief on a reorganisation, the First Tier Tribunal (FTT) found no main purpose of tax avoidance.

The FTT considered that:

The FTT allowed the appeal. It concluded that the exchange in this appeal was part of a scheme or arrangements where one of the purposes was the avoidance of Capital Gains Tax but, that purpose was not the main purpose or one of the main purposes of the arrangements.

Useful guides on this topic

An Index to Reorganisations and Demergers
You can reorganise or separate company activities and different subsidiaries using a variety of different methods. This series of super practical tax guides provide an outline of the tax treatment together with step guides and tax clearance templates.

Substantial Shareholding Exemption (SSE)
What is SSE?  When does SSE apply?

How to appeal an HMRC decision
Disagree with a HMRC decision? How to appeal, what type of decision can you appeal, what are your different options when you disagree with HMRC? What are the key steps in making an appeal?

Closure Notices
When does HMRC issue a Closure Notice? Can a taxpayer demand one? Are there appeal rights?

External link

Euromoney Institutional Investor PLV v HMRC [2021] TC08046


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