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Tax law [2026] UKFTT 517 (TC)

Wilders v Revenue and Customs (INCOME TAX - share loss relief - whether circumstances of the investment gave rise to a loss within sections 131, 137 Income Tax Act 2007 (ITA) and section 17 Taxation of Chargeable Gains Act 1992 (TCGA) - was relief denied by and of the provisions of general or targeted anti avoidance provisions (sections 16A, 30 or 38 TCGA))

Wilders v Revenue and Customs (INCOME TAX - share loss relief - whether circumstances of the investment gave rise to a loss within sections 131, 137 Income Tax Act 2007 (ITA) and section 17 Taxation of Chargeable Gains Act 1992 (TCGA) - was relief denied by and of the provisions of general or targeted anti avoidance provisions (sections 16A, 30 or 38 TCGA)) [2026] UKFTT 517 (TC) (01 April 2026)

The tribunal dismissed Mr Wilders’ appeal over share loss relief for a marine salvage investment, finding the structure triggered anti-avoidance rules.

  • Income tax
  • Share loss relief
  • Anti-avoidance
  • Capital gains tax
  • Qualifying trade
  • Loan arrangements
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Tax law [2026] UKFTT 517

Wilders v Revenue and Customs (INCOME TAX - share loss relief - whether circumstances of the investment gave rise to a loss within sections 131, 137 Income Tax Act 2007 (ITA) and section 17 Taxation of Chargeable Gains Act 1992 (TCGA) - was relief denied by and of the provisions of general or targeted anti avoidance provisions (sections 16A, 30 or 38 TCGA))

Wilders v Revenue and Customs (INCOME TAX - share loss relief - whether circumstances of the investment gave rise to a loss within sections 131, 137 Income Tax Act 2007 (ITA) and section 17 Taxation of Chargeable Gains Act 1992 (TCGA) - was relief denied by and of the provisions of general or targeted anti avoidance provisions (sections 16A, 30 or 38 TCGA)) [2026] UKFTT 517 (TC) (01 April 2026)

The tribunal dismissed Simon Wilders’ appeal concerning share loss relief for a marine salvage investment, holding that anti-avoidance provisions denied the claimed loss.

  • Income tax
  • Share loss relief
  • Anti-avoidance
  • Capital gains tax
  • Qualifying trade
  • Share-loss-relief
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Tax law [2025] UKFTT 877 (TC)

York SD Ltd & Ors v Revenue and Customs (ENTERPRISE INVESTMENT SCHEME - whether relief requirements under Income Tax Act 2007 were met)

York SD Ltd & Ors v Revenue and Customs (ENTERPRISE INVESTMENT SCHEME - whether relief requirements under Income Tax Act 2007 were met) [2025] UKFTT 877 (TC) (16 July 2025)

The Tribunal dismissed six EIS appeals, finding the companies had not commenced a qualifying trade in time and that HMRC was not estopped from withdrawing relief.

  • Enterprise investment scheme
  • Income tax act 2007
  • Qualifying trade
  • Relief withdrawal
  • Waiver and estoppel
  • Compliance certificates
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Tax law [2025] UKFTT 877

York SD Ltd & Ors v Revenue and Customs (ENTERPRISE INVESTMENT SCHEME - whether relief requirements under Income Tax Act 2007 were met)

York SD Ltd & Ors v Revenue and Customs (ENTERPRISE INVESTMENT SCHEME - whether relief requirements under Income Tax Act 2007 were met) [2025] UKFTT 877 (TC) (16 July 2025)

The Tribunal dismissed six EIS appeals, holding that the companies had not begun a qualifying trade in time and that HMRC was not bound by waiver or estoppel.

  • Enterprise investment scheme
  • Income tax act 2007
  • Qualifying trade
  • Relief withdrawal
  • Waiver
  • Estoppel
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Tax law [2024] UKFTT 870 (TC)

Putney Power Ltd & Anor v Revenue and Customs (ENTERPRISE INVESTMENT SCHEME - whether qualifying trade begun to be carried on by companies issuing shares intended to qualify for EIS relief)

Putney Power Ltd & Anor v Revenue and Customs (ENTERPRISE INVESTMENT SCHEME - whether qualifying trade begun to be carried on by companies issuing shares intended to qualify for EIS relief) [2024] UKFTT 870 (TC) (26 September 2024)

The Tribunal dismissed EIS appeals by Putney Power and Piston Heating, holding neither company had begun a qualifying trade within the statutory time limit.

  • Enterprise investment scheme
  • Qualifying trade
  • Income tax relief
  • Commencement of trade
  • Share eligibility
  • Enterprise-investment-scheme
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Tax law [2024] UKFTT 870

Putney Power Ltd & Anor v Revenue and Customs (ENTERPRISE INVESTMENT SCHEME - whether qualifying trade begun to be carried on by companies issuing shares intended to qualify for EIS relief)

Putney Power Ltd & Anor v Revenue and Customs (ENTERPRISE INVESTMENT SCHEME - whether qualifying trade begun to be carried on by companies issuing shares intended to qualify for EIS relief) [2024] UKFTT 870 (TC) (26 September 2024)

The tribunal held that Putney Power and Piston Heating Services had not begun a qualifying trade by the EIS deadline, so EIS relief was unavailable.

  • Enterprise investment scheme
  • Qualifying trade
  • Income tax act 2007
  • Commencement of trade
  • Eis relief eligibility
  • Enterprise-investment-scheme
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Tax law [2022] UKFTT 306 (TC)

VALYRIAN BLOODSTOCK LIMITED v Revenue & Customs (Enterprise Investment Scheme - risk-to-capital condition)

VALYRIAN BLOODSTOCK LIMITED v Revenue & Customs (Enterprise Investment Scheme - risk-to-capital condition) [2022] UKFTT 306 (TC) (25 August 2022)

The tribunal dismissed Valyrian Bloodstock Limited’s appeal, holding it failed the EIS risk-to-capital test and did not show a qualifying trade with long-term growth objectives.

  • Enterprise investment scheme
  • Risk-to-capital condition
  • Qualifying trade
  • Excluded activities
  • Wholesale and retail distribution
  • Enterprise-investment-scheme
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Tax law [2022] UKFTT 306

VALYRIAN BLOODSTOCK LIMITED v Revenue & Customs (Enterprise Investment Scheme - risk-to-capital condition)

VALYRIAN BLOODSTOCK LIMITED v Revenue & Customs (Enterprise Investment Scheme - risk-to-capital condition) [2022] UKFTT 306 (TC) (25 August 2022)

The Tribunal dismissed Valyrian Bloodstock’s EIS appeal, finding no objective evidence of long-term growth and development and no qualifying trade on the facts.

  • Enterprise investment scheme
  • Risk-to-capital condition
  • Qualifying trade
  • Excluded activities
  • Wholesale and retail distribution
  • Burden of proof
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Tax law [2022] UKFTT 182 (TC)

CRY ME A RIVER LIMITED v Revenue & Customs (INCOME TAX - Seed Enterprise Investment Scheme - whether capital to risk ration met - yes)

CRY ME A RIVER LIMITED v Revenue & Customs (INCOME TAX - Seed Enterprise Investment Scheme - whether capital to risk ration met - yes) [2022] UKFTT 182 (TC) (13 June 2022)

The Tribunal allowed SEIS relief for shares issued by Cry Me A River Limited, finding the risk-to-capital test was met and there were no disqualifying arrangements.

  • Seed enterprise investment scheme
  • Income tax act 2007
  • Qualifying trade
  • Disqualifying arrangements
  • Risk to capital condition
  • Seed-enterprise-investment-scheme
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Tax law [2022] UKFTT 182

CRY ME A RIVER LIMITED v Revenue & Customs (INCOME TAX - Seed Enterprise Investment Scheme - whether capital to risk ration met - yes)

CRY ME A RIVER LIMITED v Revenue & Customs (INCOME TAX - Seed Enterprise Investment Scheme - whether capital to risk ration met - yes) [2022] UKFTT 182 (TC) (13 June 2022)

The tribunal allowed Cry Me A River Limited’s SEIS appeal, finding the company met the risk-to-capital test, carried on the qualifying activity, and faced no disqualifying arrangements.

  • Seed enterprise investment scheme
  • Income tax act 2007
  • Qualifying trade
  • Disqualifying arrangements
  • Risk to capital condition
  • Seed-enterprise-investment-scheme
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United Kingdom decisions are organised by court, judge, legal area and indexed issue so a practitioner can move from a proposition to a citable authority with the surrounding context intact.

Source links and collection timestamps are retained alongside the indexed records.