Too late to claim

Negligence claims failed because they were out of time

The claimants said they had been negligently induced to invest in two tax arrangements the ‘charity shell’ scheme and the ‘Scion’ film scheme. They were told they could obtain tax relief through gift aid. It involved the investors subscribing for shares in a shell company with a further subscription if the shell was floated. The shell company would then acquire a target company and the shares of the former would be listed. The investor would gift his shares to a charity and claim tax relief on their value. The relief would be based on the value of the shares at the time of gift which was the value on listing.

The claimants said the defendants had failed to advise them that the valuation of the shell on flotation was critical and that there was a risk that HMRC would...