A share loss relief claim following a company’s failed shipwreck recovery attempt was unsuccessful, as consideration paid for the share subscription was not given wholly and exclusively for the acquisition of the shares, and as one of the main purposes of the arrangements was to secure a tax advantage.
Summary
A share loss relief claim following a company’s failed shipwreck recovery attempt was unsuccessful, as consideration paid for the share subscription was not given wholly and exclusively for the acquisition of the shares (TCGA 1992, s 38), and as one of the main purposes of the arrangements was to secure a tax advantage (TCGA 1992, s 16A).
Background
In early 2011, the appellant subscribed for shares in a company (SSVL) formed to participate in a 
