In the First-tier Tribunal, Rebecca Sheldon alongside Harriet Brown, acted on behalf of the Appellant, Coconut Animated Island Limited (CAIL). This appeal concerned whether Condition A in s257CF(3) of the Income Tax Act 2007 was met, and whether arrangements for issuing shares were “disqualifying arrangements”. This hearing explored scope of “arrangements” in s257HJ, as well as the meaning of a “relevant person” and “party to the arrangements” in context of s257CF(6) of the Income Tax Act 2007, in establishing the whether the arrangements for issuing shares were “disqualifying arrangements”. For more information on this case, please view the judgment.