The proceeds of a company purchase of own shares from its sole shareholder shortly after his acquisition of the company’s entire share capital from its previous owners was a distribution for income tax purposes, not a trading transaction. 
 
Summary 
 
The proceeds of a company purchase of own shares from its sole shareholder shortly after his acquisition of the company’s entire share capital from its previous owners was a distribution for income tax purposes, not a trading transaction. 
 
Background 
 
The appellant was an accountant, who prepared accounts for a company (CAD). In June 2013, CAD’s shareholders approached the appellant to see if he would be interested in buying the company with a view to winding it up, as they believed there was no prospect of finding a buyer for CAD and did not want the