Pike v HMRC [2014] EWCA Civ 824
April 2015 #148The appellant set up a company in March 2000 which issued shares to him. Three days later, the company issued £6m nominal of loan stock with a right to a premium on redemption of 7.25% per annum. The 7.25% accrued on a daily basis until redemption. Five days after the issue of the loan stock the loan stock was transferred into a settlement and the value of the loan stock at this time was declared as just over £2.5m. The company commenced trading thereafter.
On his annual return, the appellant claimed relief for a loss of approximately £3.5m which he claimed to have sustained on th...