Value received by persons other than the claimant
25/03/1987
Query
Would the repurchase by a company of shares held by Foir Teo disqualify the BES shareholders?
Decision
No, provided the shares are temporary redeemable shares.
Income Tax
Section 501, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:860/87B
21/06/1991
Query
Would a bank backed management buy-out (after the three years relevant period), where the bank insists on being given security over the assets of the company, constitute a receipt of value received by non-BES members?
Decision
No, where the BES money has long since been dissipated.
Income Tax
Section 501, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:922/87
13/05/1996
Query
Would capitalisation of reserves effect BES applications?
Decision
No, as long as the market value of the shareholders capital remains the same and the company does not repay, redeem, or repurchase any of the share capital.
Income Tax
Section 501, Taxes Consolidation Act, 1997
Origin: Direct Taxes International and Administration
File ref:6264/96