York SD Ltd v Revenue and Customs Commissioners [2025] UKFTT 877 (TC)

Citation:

[2025] UKFTT 00877 (TC)

Judgment Date:

16 July 2025

Summary

Appeals against HMRC’s withdrawal of the enterprise investment scheme relief relating to share issues were dismissed because the solar energy trading companies had not commenced qualifying trades within the required time periods. Although HMRC had authorised compliance certificates, it had not waived its right to withdraw the relief, nor was it estopped from doing so because the statutory scheme explicitly permitted withdrawal upon subsequent findings of non-compliance.