Availability of EIS relief
This appeal concerns the Enterprise Investment Scheme (“EIS”) and more particularly the respondents (or “HMRC”) decision to refuse to grant authority to the appellant (“Pip”) to issue compliance certificates to its shareholders under section 204(1) of the Income Tax Act 2007 (“ITA 2007”) relating to various tranches of shares issued between 17 May 2018 and 14 November 2018 (“the share issues”).