Chancery Division.

[The appeal against this decision is reported at [1994] BTC 28.]

Rattee J.

Judgment delivered 30 July 1993.

Business expansion scheme – Allotment of shares on 12 March 1993 and registered in the name of nominees after 15 March – Loans offered by banks for purchase of shares – Proposal to withdraw tax exemption if loan given for purchase of shares issued after 15 March – Whether shares ‘issued’ before 16 March 1993 – Income and Corporation Taxes Act 1988, sec. 299A inserted by the Finance Act 1993, sec. 111 in relation to shares issued on or after 15 March 1993.

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