[2008] EWHC 266 (Ch).

Chancery Division.

[The appeal against this decision is reported at [2009] BTC 39.]

Peter Smith J.

Judgment delivered 19 February 2008.

Capital gains tax – Enterprise investment relief – Issues of shares – Informality – ‘Value received’ provisions – Whether payment made to company before issue of shares to be treated as loan caught by anti-avoidance provision – Whether payment to company to be treated as capital contribution – Whether payment to company impressed with Quistclose trust – Whether single or separate share issues – Taxation of Chargeable Gains Act 1992, Sch. 5B, para. 13.

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