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FTT considers main purpose test in applying the transactions in securities regime to a buyback of EIS shares (Osmond v HMRC)

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Published on: 20 May 2024
Published by a LexisNexis Tax expert

Table of contents

  • Why it matters
  • Case details

Article summary

Tax analysis: In Osmond v HMRC, the First-tier Tax Tribunal (FTT) dismissed the taxpayers’ appeals concerning share buybacks that were intended to crystallise capital gains tax (CGT) relief under the Enterprise Investment Scheme (EIS), deciding that in law they had a main purpose of obtaining an income tax advantage under the transactions in securities (TIS) anti-avoidance provisions.

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Jurisdiction(s):
United Kingdom

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