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Share loss relief claim

The taxpayer claimed loss relief on his investment in Geezer Telecom Ltd because the shares had become worthless when the company had entered into administration.

He said it was agreed with G the sole shareholder that he would invest in the company and receive 225 shares in return.

HMRC accepted that the taxpayer had made payments to the company between June 2011 and May 2012 but the company did not issue any shares to him. Instead the 100 £1 shares were subdivided into 1 000 10p shares. In July 2011 G transferred 225 shares to the taxpayer for a nil consideration. In May 2012 the taxpayer transferred those shares to G also for a nil consideration. As a result the taxpayer must therefore have lent the money to Geezer. He paid nothing for the shares and received nothing for them when...