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Our local football club client operates through a limited company. In August 2001, it invited individuals to subscribe for £50 shares; £10 payable on application and further payments of £10 to be made yearly thereafter until August 2005. More than 50% of the shares are owned by three individuals, so the company is 'close'. Fortunately, these three individuals all paid the total sum for their shareholding in 2001, as did a number of other shareholders.
Our local football club client operates through a limited company. In August 2001 it invited individuals to subscribe for £50 shares; £10 payable on application and further payments of £10 to be made yearly thereafter until August 2005. More than 50% of the shares are owned by three individuals so the company is 'close'. Fortunately these three individuals all paid the total sum for their shareholding in 2001 as did a number of other shareholders.
HMRC have enquired into the corporation tax return for the year ended 30 June 2004 concerning the application of TA 1988 s 419 to the unpaid share capital. I have asked the Officer whether there is any precedent for applying s 419 to uncalled share capital and pointed out that the section normally applies to loans and advances made to members of a company. It seems perverse to apply...
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