Share transfers

The taxpayer company formed in Jersey on 12 September 2007 when it issued 10 000 no par ordinary shares to Biffa Corporate Holdings. It issued another 200m shares to the same business for £200m on 26 September.

Biffa Corporate Holdings transferred its shares on the same day to Biffa Holdings by share exchanges. The latter business sold 200m shares for £200m the next day to the taxpayer which cancelled them.

The taxpayer then issued 200m shares to Biffa Corporate Holdings for £214m and under a separate agreement Biffa Holdings agreed to buy 200m from Biffa Corporate Holdings on 26 September 2008 for £214m.

Nearly one year later the taxpayer issued 200m shares for £214m to Biffa Corporate Holdings which it sold to Biffa Holdings for the same price.

Biffa Holdings claimed the difference between the £200m it received on the sale of the...