Enterprise investment scheme (EIS) meaning

In this issue: Trusts UK taxes for Private Client HMRC Manuals tracker Tax avoidance, evasion and non-compliance Digital assets and cryptoassets International Question of the week Additional Private Client updates this week Daily and weekly news alerts LexTalk®Private Client: a Lexis+® community New and updated content Dates for your diary Trackers New Q&As Useful information Trusts Court dismisses claim for declaration of beneficial interests in shares (Fulstow v Francis) In Fulstow v Francis [2024] EWHC 2122 (Ch), the Chancery Division rejected the claimants’ action concerning shares in Capital Land, a company that owns development land. The claimants asked for declarations confirming their beneficial interests in Capital Land shares held by the defendant, together with an order compelling him to sign a stock transfer form to pass to them the shares they asserted were beneficially theirs. The High Court found there was no binding agreement for the transfer of...

On 26 November 2025, Rachel Reeves, the Chancellor of the Exchequer, presented the Labour administration’s second Budget, widely referred to simply as Budget 2025. On the same day, the Office for Budget Responsibility (OBR) set out its economic and fiscal outlook for the UK. Proceedings opened poorly, and chaotically, with an OBR forecast leaking amidst a slew of prior government-led briefings and the release of a frustratingly static index of ‘Budget 2025 tax related documents’ to which hyperlinks were not inserted until close to 8pm, together with a piecemeal, stop‑start publication of tax information across scattered web pages, sending readers on a fruitless treasure hunt for clarity or coherence and with no appearance whatsoever of the Overview of Tax Legislation and Rates (OOTLAR). Headline measures comprised, among other items, extending, for another three years to April 2031, the existing personal allowance and income tax bands for taxpayers, and increasing income tax rates applied to property, savings and dividend receipts, as well as imposing employer and employee National Insurance contributions (NICs)...

Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC [2025] UKUT 28 (TCC) The taxpayer company was a special purpose vehicle incorporated to commercialise intellectual property in a pre-school animation concept. It formed part of a wider group through which third party investors placed capital into special purpose vehicles. The plan was that those third party injections would qualify for the Seed Enterprise Investment Scheme (SEIS) and the Enterprise Investments Scheme (EIS), respectively. Investment was made by third party investors into such special purpose vehicles through the group, and the structure was intended to secure those outcomes. As part of the arrangements, the company entered into a production services agreement (PSA) with another group company, under which that company would provide all aspects of production and delivery of episodes of the animation, in return for payment. Although the tribunal allowed the company’s appeals on the EIS trading requirement and the risk-to-capital condition, the FTT concluded there were disqualifying arrangements within ITA 2007, s 178A,...

The enterprise investment scheme (EIS) It is primarily intended to boost investment in smaller, higher‑risk trading companies by granting a range of tax reliefs to individual investors who acquire newly issued shares in such companies. The EIS rules are prescriptive and contain numerous conditions that must be satisfied, including those relating to: the individual investors the issued shares the issuing company This Practice Note centres on the conditions that apply to the individual investor. Those conditions are outlined in the context of the income tax relief afforded by Part 5 of the Income Tax Act 2007 (ITA 2007). References to the equivalent capital gains tax (CGT) provisions are included where appropriate. For information on the remaining conditions, see the following Practice Notes: EIS—conditions for relief: issued shares, the funds raised and the arrangements in general EIS—conditions for relief: issuing company EIS—conditions for relief: qualifying trades For a summary of tax reliefs available...

CGT reliefs most relevant to Private Client Multiple reliefs exist to lessen or defer capital gains tax (CGT) arising on the disposals of both business and personal interests...

Principal private residence relief Where an individual holds more than one residence, they may, by formally giving notice to HMRC, nominate which property is to be treated as their main residence for principal private residence (PPR) relief purposes. In these circumstances, any period of actual ownership (by election) of the elected PPR should be regarded as fully exempt from capital gains tax (CGT), provided there has been a previous period of actual occupation. In addition, the last nine months of the period of ownership are always deemed to be a period of occupation. Before 6 April 2014, the exemption covered the final 36 months of ownership; it was reduced to 18 months from 6 April 2014, and halved again to nine months for disposals on or after 6 April 2020. Individuals who are disabled or residing in a care home, and who have no other property on which PPR relief can be claimed, continue to benefit from the 36‑month final period exemption...