Seed capital meaning

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,...

Successive UK governments have aimed to cement the UK as one of the world’s most appealing settings for innovation and enterprise. To that end, a wide-ranging suite of tax incentives has been rolled out to encourage innovative companies, supporting both investors and trading entities, and assisting businesses at every phase of a business’s life cycle. These incentives include: R&D tax reliefs patent box business asset disposal relief (previously entrepreneurs’ relief) capital allowances for purchases of: knowhow patents, and plant and machinery venture capital trusts the enterprise investment scheme, and the seed enterprise investment scheme This Practice Note outlines the UK position on key tax considerations when determining how to structure an innovative business with international or global aspirations. The observations are general in nature and work on the basis of a clean slate; revisiting an existing IP ownership arrangement will inevitably demand a bespoke solution (notably...

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...