Dwan & ors v Commissioners for HMRC [2022] WTLR 501
Summer 2022 #187Five shareholders of Taskcatch plc made gifts of shares in the company to various charities and then claimed tax relief on the basis of the value of such shares at the dates of the gifts. Mr Dwan gifted 500,000 shares on 31 March 2003 and claimed relief on the basis of their value being 32.5p per share. On 31 March 2003, a small trade of shares in Taskcatch plc was registered on AIM at a price of 32.5p per share. Also on 31 March 2003, shares in Taskcatch plc were issued at the implied price of 7p per share to the vendors of a company that was being acquired. On 5 October 2004, Mr and Mr...